THE FBI INFORMATION REQUEST - SPECIFICS

Misinformation on KSO reactors in the GAO Report

last update January 20,2001

Introduction

During a meeting on February 3, 1998, the FBI requested specific examples of criminal activity at the Knolls Atomic Power Laboratory (KAPL) regarding the lack of Emergency Core Cooling Systems on all Nuclear Power Plants at the Kesselring Site Operations (KSO). This page presents informationregarding the lack of Emergency Core Cooling Systems as well as the lack of Containment Vessels and the lack of a Separate Control Room for reactor operators.

The GAO Report of 1990/1991 contains a variety of errors and omissions concerning a variety of issues. Of all of these errors and omissions, I believe the most egregious to be in regard to the lack of those basic safety features required on all commercial nuclear power plants, particularly those relating to Emergency Core Cooling Systems and Containment Vessels.

The issues regarding the lack of these safety features on commercial nuclear reactors would be a crime punishable as felonious activity. These are issues related to the health and safety of the sailors operating the nuclear power plants as well as those citizens living within a short to a significant distance from the nuclear reactors. The military has no legal right to expose civilians to the type of dangers associated with the many types of reactor accidents that are possible as the result of operating high power nuclear reactors.

The numbers and types of accidents which have occurred at the KSO is testimony to the fact that accidents can and do happen at the KSO. Reactor accidents have occurred that came very close to reactor meltdowns and some have caused significant releases of radiation to the atmosphere. The Navy/DOE/GE have simply failed to notify anyone of these accidents. The Navy/DOE/GE does not consider this inattention to detail lying, it is simply failing to tell the truth. The United States Government and it's contractors like to make such a distinction so they can feel better about themselves. That is why the Nuclear Navy continues to employ Mr. Robert Guida as a spokesman for NR. Mr. Guida had the effrontery to lie to the Governor of Idaho concerning the kind and amount of radioactive material that would be sent to that State. A discussion of that particular lie can be found in: ISBND-16 D43425-4, 103rd Congress, July 28, 1993. The State of Idaho also had to sue the DOE/NR concerning incorrect statements made to Idaho officials concerning the kind and amount of radioactive material that would be sent to that State. Lying is not new to the Naval Reactor program, the lies are simply keep hidden from the American public.

The General Electric Company, Naval Reactors[KAPL] and the DOE meanwhile continue to hide behind a myriad of laws set up to protect contractors involved in all aspects of the Nuclear Industry. The Naval Reactor Program continues to proclaim that the program is exempt from oversight by virtue of an executive order written by President Reagan in 1982. The Order is known as Executive Order 12344. A review of the Order shows no exemption from oversight either implied or stated. The order does, in fact imply, that the NR program should at least meet or exceed the criteria established for all similar activities in the Country. KSO does not even come close to meeting minimum standards established for all other facilities.

The FBI, as expected, failed to take action regarding the issues presented in the following letter. I did, however, receive a letter from the organization that oversees the FBI [U. S. Department of Justice - Office of Professional Responsibility] dated November 2, 1998 which states, in part, that:

" United States Attorneys are vested with broad discretionary authority in determining whether alleged violations of federal law should be pursued. In the absence of specific information showing that that authority has been corruptly, or otherwise inappropriately, exercised, this office will not review decisions made pursuant to that authority".

In other words if its an agency sponsored by the federal government we are not going to investigate. This failure to investigate could easily be construed as an attempt by the FBI to aid and abet in a cover-up by the General Electric Company, Knolls Atomic Power Laboratory and The United States Navy.


Letter to the FBI and ignored by the FBI and Justice Department

April 1, 1998

John P. Shannon
262 Jones Road
Saratoga Springs, NY 12866

518-587-3245

Mr. Michael Bassett, Special Agent of the FBI

Mr. Robert P. Storch, Assistant US Attorney
James T. Foley U.S. Court House
445 Broadway
Albany, NY 12207-2924

518-465-7551
518-431-7463(F)

Dear Mr. Bassett:

During a meeting on February 3, 1998, you requested specific examples of criminal activity at the Knolls Atomic Power Laboratory (KAPL). This letter presents detailed information on the deficient attention to, and violation of, accepted reactor safety requirements at the Kesselring Site Operation (KSO), located in West Milton, New York, and on the coverup thereof, as contained in the General Accounting Office (GAO) report following review of that facility.

Background: Between 1950 and 1972, Naval Reactors (NR) constructed four nuclear power plants at the KSO for nuclear propulsion research and for training of Navy crews for the nuclear fleet. These power plants were exact replicas of the reactor compartment and engine room of nuclear-powered submarines and destroyers. Previously, such facilities had been situated only in remote locations, such as the Idaho Nuclear Test Station {approximately forty miles from the nearest city}, thereby taking advantage of distance as an important safeguard to public health and safety in the event of a nuclear accident. Selection of the KSO site in a highly populated recreational region of upstate New York, was a serious compromise of this conservatism a concession by Naval Reactors to obtain participation by the General Electric Co. (GE) in the Naval Reactor Program. All commercial nuclear reactors, many located in populated areas, are mandated by Nuclear Regulatory Commission (NRC) regulations to incorporate containment systems to prevent release of radioactivity to the environment and emergency core cooling systems (ECCS) to prevent core meltdown in the event of a loss of coolant accidents. The KSO reactors have lacked these vital safety features for 45 years, thereby placing both employees at KSO and the general public at unnecessary, and illegal, risk. The alleged lack of these important safety features, along with numerous other safety issues, led Congressman Mike Synar to request a GAO review of the environment, health, and safety practices at the Department of Energy's Naval Reactor Program facilities. The GAO issued a report, GAO/RCED-91-157.

The GAO report: For whatever reason, the GAO report is filled with misinformation and falsehoods about containment and ECCS. In fact, this report, in itself, reveals glaring inconsistencies in Naval Reactors actions at KSO, as related to both containment and ECCS, which demand full investigation and, where warranted, prosecution of those supplying such false information to the U.S. government. Furthermore, based on its grossly flawed content, which has been repeatedly used in courts of law, before Congress, in environmental hearings, and other defenses of the Naval Reactors program, this report must be recalled. Details of falsification follow, with italics identifying our comments concerning NRC safety criteria and statements contained in the GAO report.

SAFETY MEASURES: The GAO reports, "Based on our evaluation, Naval Reactors laboratories have provided safety measures that are consistent with commercial nuclear reactor requirements." (Page 20).

NRC safety measures required of commercial reactors are extremely demanding particularly with regard to containment systems and emergency core cooling systems( as outlined below). Those of us raising allegations as to lack of these vital safety features have, collectively, more than 100 man-years of direct scientific and engineering input into the design, startup, operation, training, and maintenance of the KSO prototypes. We state unequivocally, and will repeat under oath, that based on our active in-depth involvement in the Naval Reactors program, no such safety measures were ever provided for, or added to, the prototype reactors. There are no KSO safety measures related to containment or emergency core cooling that are consistent with commercial reactor requirements.

CONTAINMENT SYSTEM

NRC Criterion 16 -- Containment design. Reactor containment and associated systems shall be provided to establish an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment and to assure that the containment design conditions important to safety are not exceeded for as long as postulated accident conditions require.

NRC containment requirements address a containment system, not a simple containment structure. To assure that containment design pressure and temperature is not exceeded, the containment structure must include a substantial internal heat removal system to suppress temperature and pressure and a hydrogen control system to preclude the potential explosion of "hydrogen generated from a 100% fuel clad metal-water reaction." Naval prototypes lack this system in its entirety, and there is zero possibility that, by chance, any form of equivalency inadvertently crept into the design.

CONTROL ROOM

NRC Criterion 19 -- Control room. A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions.

The NRC requires reactor control rooms be remote from containment so that habitability is assured throughout any accident. Commercial control rooms are located external to, and distanced from, the containment structure. Control rooms for Naval prototypes are located inside the ship's hull, the purported containment. In the event of a worst case nuclear accident, the operators will not survive and control of the reactor will be lost during the evolving accident.

The GAO report also states that, ". . . one prototype at Knolls' Kesselring site has a massive sphere around it to contain radioactive material if an accident occurs." (Page 21).

A 125-ft diameter steel sphere housed the first prototype at KSO. This sphere is identified in the GAO report as a containment vessel, i.e., a sphere to contain radioactive material in the event of an accident. Thus, the first submarine hull was not considered to be containment. Otherwise, there would have been no need for a massive sphere. The three follow submarine prototypes at KSO had no such sphere. This statement, in and of itself, substantiates the fact that Naval Reactors is well aware of what containment involves and is fully aware that submarine hulls do not meet NRC basic safety criteria for containment.

EMERGENCY CORE COOLING SYSTEM

NRC Criterion 35 -- Emergency core cooling. A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.

NRC emergency core cooling requirements are met on commercial plants by highly sophisticated, reliable, and redundant equipment. Naval prototypes lack this system in its entirety. Neither fire hoses located 20 miles distant, jury-rigged piping, nor rugged design are equivalent. And, there is zero possibility that, by chance, any other form of equivalency inadvertently crept into the design.

"The GAO report states, "Consequently, in 1979, Naval Reactors decided to enhance safety at the prototypes by upgrading or adding safety systems." (Page 21)

In 1979, following the reactor meltdown at Three Mile Island, where radioactive release was prevented by an NRC mandated containment system, Naval Reactors belatedly realized that long term lack of an ECCS on the aging prototypes was no longer a viable risk. A major site wide construction project was initiated to provide ECCS to all four prototypes. Ten years later, at the time of the GAO review, this project was still underway, and the ECCS was not available. The GAO report indicates that all prototypes would have ECCS by 1991. Fast forward. . . the project failed and was discontinued after GAO exited. Today, in 1998, the two remaining prototypes do not have ECCS. . . no safety systems were added, and no equivalent safety system exists. Although this statement in the GAO report purposely avoids identifying the 1979 effort as an ECCS addition, the date identifies the project. This statement, and the action to which it refers, in and of themselves, substantiate that Naval Reactors was, and is, fully aware that the prototypes never had ECCS, or any equivalent protection, and do not now have ECCS. In fact, if as stated under Safety Measures, "safety systems consistent with NRC criteria were in place," then Naval Reactors should be prosecuted for waste, fraud, and abuse, under the Federal Civil False Claims Act (Qui Tam) for spending hundreds of millions of dollars in a failed attempt to construct an ECCS which was not needed.

The GAO report further states that, "While the identification and description of many of these (safety) systems is classified, our nuclear engineer's review of the reactor designs and systems concluded that the prototypes will meet the intent of NRC safety criteria for normal operations and accident conditions." (Page 21).

Naval Reactors has repeatedly, and illegally, used "classification" as a means of concealing the fact that vital safety systems do not exist on the prototype reactors. Neither the containment systems nor the ECCS, or any mystery equivalence, can be classified . . . because they do not exist. Without these systems, there is absolutely no way that the prototypes can meet the intent of NRC safety criteria. Contrary to Chapter 5 of the GAO report, this statement is a prime example of how GE/NR/SNR/DOE management violates and abuses the classification system.

Summary: The Naval Reactor prototypes at KSO lack two vital safety features, namely containment systems and ECCS. Statements quoted from the GAO report under "Containment System", constitute prima facie evidence that GE/NR/SNR/DOE management knowingly, and willfully, made false claims that submarine hulls provide containment. Statements quoted from the GAO report under "Emergency Core Cooling System" constitute prima facie evidence that GE/NR/SNR/DOE management knowingly, and willfully, made false claims that the prototypes contained features equivalent to ECCS. These false claims are sufficient cause to recall the GAO report and to bring charges against appropriate GE/NR/SNR/DOE management for flagrant violation of 18 U.S.C. 1001, 18 U.S.C. 1516, 40 U.S.C. 333 and, perhaps, the Federal Civil False Claims Act (Qui Tam).

Robert J. Stater
Licensed -Nuclear Engineer

And

John P. Shannon, Major USMC, (R)
Former Manager of Nuclear Criticality Safety, Industrial Safety and Industrial Hygiene at
The Knolls Atomic Power Laboratory and

Nuclear Reactor Physicist

cc:/ Senator Orin Hatch (R-Utah)

Senate Judiciary Committee
131 Russell Senate Office Building
Washington, D.C. 20510

Members of the United States Senate


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