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žGSI-189 chronology:

  • 1998:  First public mention that Sandia is having trouble “resolving” DCH issues for ice-condensers (CCFP > 0.1)
  • April 2000:  Publication of NUREG/CR-6427 after long delay
  • Sept. 2000:  Staff proposes establishing GSI to assess costs and benefits of additional hydrogen control
  • May 2001:  GSI-189 established
  • Dec. 2001:  Commission requests that staff resolve GSI-189 “expeditiously”
  • Nov. 7, 2002:  Jack Rosenthal (at ACRS meeting):  “I personally believe that we have done enough number-crunching over 20 years, that it is time to make a decision.”
  • Nov. 13, 2002:  ACRS recommends that GSI-189 be resolved by voluntary industry initiative (SAMG) and not by order or rule
  • Dec. 2002:  RES recommends to NRR that further regulatory action is warranted
  • Aug. 2003:  Commissioner McGaffigan approves revision of 10 CFR 50.44 but “hope[s] that GSI-189 will soon be resolved with appropriate additional measures being required (emphasis added)…”
  • Sept. 2003:  “Risk-informed” 10 CFR 50.44 is published; only contains provisions that reduce regulatory burden
  • Nov. 2003: ????? (Can it really take NRR over a year merely to request a voluntary industry initiative?)
  • žContinued acceptance of nuclear power in the United States post-Chernobyl is largely predicated on the belief that US reactors have pressure-resisting containments
  • For SBO sequences, ice-condensers essentially have no containment at all
  • A functioning containment is not a safety “enhancement” but a requirement for adequate protection
  • žFocus on prevention only does not fully address common-mode vulnerabilities that can be exploited by terrorists
  • žEven if calculated cost-benefit differentials are marginal, NRC should give considerable weight to defense-in-depth when determining whether regulatory action is needed
žUrgency of this issue requires mandatory regulatory action (not inconsistent with a performance-based approach)
  • MOX program at Catawba and McGuire will soon increase public health risks
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