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1l 20, 2011
The Honorable Gregory Jaczko
Chairman, U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
Dear Chairman Jaczko:
I am writing to request that the Nuclear Regulatory Commission (NRC)
begin examining seismic and tsunami hazards, operational issues,
plant security, emergency preparedness, spent fuel storage options
and other elements of a nuclear power plant’s “design basis” within the
scope of the relicensing process.
The current relicensing process is focused entirely on identifying and
managing the detrimental effects of aging plant facilities. The process
does not reevaluate the threat assessment that formed the basis of
the plant’s original design.
I believe that our understanding of many threats – especially seismic
threats, tsunami threats, spent fuel risks, and terrorist threats – has
improved dramatically since most nuclear power plants were originally
designed and licensed thirty or more years ago. Relicensing these
facilities offers a unique opportunity to review the original assessment
of potential threats, in order to ensure that a facility is designed to
endure all threats safely.
I appreciate that the NRC continuously reviews threats, and has
required upgrades to address newly understood concerns outside of
the relicensing process. For instance, the Commission issued rules to
lower the risk of hydrogen explosions when this threat was identified in
the 1980s. However, the ongoing assessment process places the
burden of proof on the NRC to demonstrate that a design or
operational modification of a fully licensed facility is necessary. In
contrast, the relicensing process would place the burden of proof on
the facility to demonstrate that it is designed to endure and survive all
potential threats.
Recent events demonstrate that thirty year old threat assessments can
be devastatingly inaccurate. In Japan there have been two
earthquakes in four years that exceeded the “design basis” of nuclear
plants. In California, researchers have recently found new faults close
to nuclear power plants, and tsunami experts have learned that
submarine landslides can generate local tsunamis far larger than previously believed.
Finally, recent research has demonstrated the
susceptibility of storing radioactive spent fuel in densely packed pools.
These new threats logically should be considered in a relicensing
process, just as they would be in the licensing of a new nuclear power
plant in the United States.
I strongly encourage the NRC to modify its relicensing policies in order
to assure a full reexamination of design basis elements, including
seismic and tsunami hazards, operational issues, plant security,
emergency preparedness, and spent fuel storage options. If you have
any questions or concerns about this request, please do not hesitate to
contact me. I look forward to working with you to ensure that the
United States has the world’s safest nuclear industry.
Sincerely,
Dianne Feinstein, Chairman
Subcommittee on Energy and Water Development