Friends of the Earth Challenges New AP1000 Reactor Design as Comment Period Ends

In comments submitted today as part of the formal review to determine whether reactors of the Westinghouse AP1000 design will be licensed for construction in the United States, Friends of the Earth challenged both the integrity of the review process employed by the Nuclear Regulatory Commission and the safety flaws in the proposed reactor design.

This reactor is the first new design in decades being considered for construction in the U.S. Though questions linger about the design's safety, and even though the NRC has not conducted additional analysis in the wake of the Fukushima disaster in Japan, the NRC is sticking with an industry-backed fast-track licensing approach.

The 75-day formal comment period on the AP1000 "rulemaking," which began with the publication of an announcement in the Federal Register on February 24, closes today. Included in the record are more than 14,000 comments submitted throughout the public comment period by Friends of the Earth activists, asking that the comment period be extended. This number of comments appears to be a record number submitted in an NRC rulemaking procedure. Yet, today the NRC rejected the call to extend the comment period, despite the thousands of public requests.

"The AP1000 reactor design is flawed, but due to industry pressure it is being rushed through an inadequate licensing process that is not serving public health or safety," said Tom Clements, Southeastern Nuclear Campaign Coordinator with Friends of the Earth. "The Nuclear Regulatory Commission must stop this process until it has time to consider the multitude of lessons about reactor design and operation which will eventually be learned from the Fukushima accident. Failure to do so could well be a recipe for a nuclear disaster here in the U.S."

Nuclear engineer Arnie Gundersen and the staff of Fairewinds Associates analyzed the design of the AP1000 reactor and found many aspects lacking, as cataloged in the comments formally submitted to the NRC by Friends of the Earth. The comments state that claims made about the safety of the reactor's containment structure "are not based upon sound scientific analysis and engineering review, but appear instead to be based upon the mythical dreaming of an aggressive industry and its captive regulator."

According to the comments authored by Gundersen and Fairewinds, the passive cooling system of the AP1000, which lacks a robust containment shell, merits close scrutiny. The cooling of the 1.75-inch steel containment shell is dependent upon a vulnerable 800,000-gallon tank precariously perched on top of a vented "shield building," a structure whose integrity has been questioned by even the lead NRC engineer in the design review. Fairewinds states: "This single source of cooling water perched atop the shield building is unique to the AP1000 design and Westinghouse's reliance upon it creates a single point of vulnerability that has not been thoroughly evaluated by industry regulator NRC due to the rush to AP1000 certification and licensure."

The comments also identify problems with a computer analysis of the design conducted by the NRC, arguing that the "review has uncovered analytical problems with the containment design computer codes applied to both the AP1000 containment analysis and the analysis of the AP1000 shield building."

The submission goes on to highlight earlier comments by a former Westinghouse reactor design employee, Dr. Susan Sterrett, who raised numerous, as of yet unanswered, questions about the methodology employed by both Westinghouse and the NRC in relation to the AP1000 design. Dr. Sterrett alleges that Westinghouse improperly based the AP1000 design on aspects of the AP600 design and that the NRC and the Advisory Committee on Reactors Safeguards (ACRS) did not thoroughly review this choice by Westinghouse.

The remarks prepared for Friends of the Earth state that "it appears that the ACRS and NRC have done a woefully inadequate review of both Dr. Sterrett's and Fairewinds Associates' AP1000 legitimate safety and engineering concerns in order to meet industry demand for an accelerated review process and fast-track licensure of a woefully unreviewed and untested new reactor design."

"We expect a full and detailed response to every point raised in our comments on the AP1000 design. The NRC must convince a skeptical public that all lessons learned from the Fukushima accident will be incorporated into the design before it is approved," said Clements.

Failure by the NRC to adequately take into account concerns about the reactor design and information flowing from the Fukushima disaster could lead to a legal challenge if the final rule certifying the design is approved.

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Notes:

1. Link to Fairewinds comments prepared for Friends of the Earth and submitted to NRC on May 10, 2011: https://www.foe.org/sites/default/files/Gundersen_FOE_Report_5-10-2011.pdf

2. "AP1000 Design Certification Amendment" published in Federal Register, February 24, 2011, https://edocket.access.gpo.gov/2011/2011-3989.htm

3. Fairewinds Associates, https://www.fairewinds.com/, tel. 802-503-3890, contact@fairewinds.com

4. New Reactor Model Faces Legal Challenge, https://www.foe.org/new-reactor-model-faces-legal-challenge