Pilgrim Watch Comment Regarding Additional Requirements For Containment Venting Systems For BWRs With Mark I And Mark II Containments In Support Of Filters And Rupture Discs

Hello:
Attached please find Pilgrim Watch Comment Regarding Additional Requirements For Containment Venting Systems For BWRs With Mark I And Mark II Containments In Support Of Filters And Rupture Discs prepared for the NRC Commissioners that will vote on whether or not to require filters and rupture discs on vents used to relieve pressure from the containment in a severe accident.

In a severe accident the amount of radioactivity released offsite from an unfiltered vent would be very large and damaging. It makes no sense not to add a filter to protect our families and property from contamination. Filtered systems are available, tested and in use today - for example  in Sweden, Germany, France, Switzerland and will be installed in Slovenia and Japan that learned the hard way the danger of not requiring filters and rupture discs before the accident.

Rupture discs are necessary so that neither water nor electrical supply is needed and operator intervention is not necessary to actuate the venting system to save containment in a pressure buildup.
Lessons learned from Fukushima showed the importance of requiring reactors designed like Mark I & II’s in the U.S. to install filtered DTV’s in order to:
     ·  Protect public health in the event that it is necessary to release.

     ·  Assure operators follow orders to open the vent. As in Japan, properly trained operators here are likely to decide not to open the DTV when they should because they fear the effects offsite of significant unfiltered releases.

As part of the Fukushima Lessons Learned Task Force, NRC Staff assigned to study whether to recommended filtering, did do (November 2012). It only made sense when considering that during normal operations and design based accidents gaseous releases are filtered but they are not filtered during severe accidents when the releases offsite will be the greatest.

Please consider contacting the NRC Commissioners in support of the attached comments ASAP; and also alert your members and elected officials to do the same.  I attached a word version for your convenience.

Vents affect all Mark I and Mark II BWRS that includes: Mark I BWR Reactors: Browns Ferry 1, 2 & 3 (AL); Brunswick 1 & 2 (NC); Cooper 1 (NE) Dresden 2 & 3 (Il); Duane Arnold 1 (IA);  Fermi 2 (MI);  Fitzpatrick 1 (NY);    Hatch 1 & 2 (GA); Hope Creek 1 (NJ); Monticello 1 (MN); Nine Mile Point 1 (NY);  Oyster Creek 1 (NJ);   Peach Bottom 2 & 3 (PA) ; Pilgrim 1 (MA); Quad Cities 1 & 2 (IL); Vermont Yankee 1 (VT). Mark II BWR Reactors: Columbia (WA); LaSalle, 1&2 (IL); Limerick 1 &2 (PA); Nine Mile (NY); Susquehanna, 1&2(PA)

Thank-you !

Mary Lampert
Pilgrim Watch, Director
148 Washington Street Duxbury, MA 02332