Maggie Gundersen: Hi I'm Maggie Gundersen with Fairewinds Associates, and I'm here this afternoon (Thursday, May 26th, 2011) to do an intro to Arnie's presentation before the NRC Advisory Committee on Reactor Safeguards.  This afternoon, the ACRS held a special meeting to assess the status of the on-going multiple accidents at the Fukushima Nuclear Plants. Unfortunately, whether intentionally or unintentionally, Arnie's presentation was interrupted continuously by whispering and rustling of many different papers.  While the government and industry  participants enjoyed nearly two hours to present, Fairewinds was granted only five minutes.  You'll see for yourself how tough it is as an individual or an expert witness to testify to the NRC.

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Arnie Gundersen (prepared presentation):

Good afternoon Mr. Chairman and members of the Advisory Committee on Reactor
Safeguards.

I speak to you today as the Chief Engineer of Fairewinds Associates, Inc, and have not been retained by any group to make a statement at this meeting. Although there are many issues that must be resolved as a result of the nuclear accidents at Fukushima, I will focus on the single issue of containment integrity in the brief time you have allotted to me.

I first wrote to you, the ACRS in 2005 to express my concern regarding Vermont Yankee and the net positive suction head (NPSH) waiver that the ACRS granted to Vermont Yankee.

In 2008 Fairewinds was retained by CCAM to analyze the Millstone 3 containment. I spoke twice to the ACRS regarding my belief that the containment volume to power ratio at Millstone 3 is the smallest of any Westinghouse four-loop plant in the world. At that
meeting, the ACRS staff acknowledged that it does not have the capability to analyze containment systems.

In 2009 Citizen Power retained Fairewinds to analyze the hole found in the Beaver Valley containment. That analysis was also discussed by the ACRS. In 2010 when I met with you as a candidate for an opening on the ACRS, we discussed NPSH and its relation to containment integrity. I noted then that the Browns Ferry units had not been allowed the NPSH credit, yet ACRS granted the NPSH credit to Vermont
Yankee five years earlier. It is illogical that that the people of Alabama have more accident protection than the people of Vermont.
 
In 2010 the AP1000 Oversight Group retained Fairewinds, and in April 2010, Fairewinds provided you with a report detailing a long history of containment failures around the country. In June 2010 Attorney Runkle and I met with you for an hour and a half to
delineate my concerns regarding doubts about the containment integrity of the AP1000 design. In December of 2010 I wrote to you again notifying you of a significant amount of additional information about containment failures and flaws because at the October
2010 ACRS meeting, the NRC staff informed the ACRS that the NRCʼs calculations assume that there is zero leakage in the Mark 1 design.

Each time I have contacted you, the containment integrity data has been rebuffed and ignored. The accidents at the Fukushima Mark 1 BWR reactors have confirmed my belief that leakage of a nuclear containment cannot be based upon the assumption of a leakage rate of zero used by the NRC. This week, Tokyo Electric Power Company (TEPCO) has finally acknowledged that all three of the Fukushima Mark 1 containment systems are leaking significant radiation into the environment, and at least Units 1 and 2 began leaking on the first day of the accident. Unfortunately, the possibility of such containment failures, to which I have alerted you for the past six years, have been proven correct.

It is no surprise to me that containment systems have a long history of leaking and have now failed three times at Fukushima, yet it apparently comes as a major surprise to this advisory body and the NRC.

The ramifications of nuclear reactor containment leakage and failure the NRC and this body must consider are:

1. The SAMDA analysis for the Westinghouse AP1000 design is based upon false calculations that there is zero probability of a containment leak of any magnitude. The historical record prior to Fukushima proved this assumption false, and the Fukushima containment failures require that the AP1000 design be reanalyzed and retrofitted with advanced charcoal filters on the top of the shield building.
 
2. This advisory body has granted NPSH credits to numerous reactors around the country in violation of Regulatory Guide 1. Today, with a simple stroke of a pen, the ACRS can acknowledge its erroneous decision by requesting that the NRC revise the licenses of all reactors so that every reactor is in compliance with Regulatory Guide 1. And, with this one simple pen-stroke you can make all of
the reactors applying the NPSH credit immediately safer than they are today.

3. Everyone sitting on the ACRS today knows that the pressure suppression containments on General Electric BWRʼs were inadequate when they were first designed. As a result of that design inadequacy, boiling water reactor containment vents were added in 1989 to prevent containment over-pressurization. Currently there are 23 Mark 1 containment systems in operation. All 23 Mark 1ʼs have vents that were added as a Band-Aid fix. It is time for the ACRS to evaluate containment venting to determine whether or not it any of these reactors be allowed to continue operation.

4. Moreover, ACRS should stop the license renewals of any BWR until the Fukushima accidents have been completely analyzed.

For the record, Fairewinds finds it disconcerting that both NEI (Nuclear Energy Institute) and DOE (Department of Energy) have been granted one hour each to make presentations to this body, when NEI and DOE are responsible for the promotion of nuclear power. I have brought these containment integrity issues to your attention for more than six years. In closing, I strongly suggest that each of you as members evaluate the bias you bring to the table when listening to experts with whom the nuclear industry disagrees.

Thank you for your time. I will gladly brief you in detail if you so choose.