ML18347A758
| ML18347A758 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/27/1977 |
| From: | Reizen M Consumer Energy Co, State of MI, Dept of Public Health |
| To: | NRC/Chairman |
| References | |
| Download: ML18347A758 (6) | |
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SlAft ur MIUllGAM DEPARTMENT OF PUBLIC HEALTH P.O. Box 30035 WILLIAM G. MILLIKEN, Governor 3500 N. LOGAN, LANSING, MICHIGAN 48909 MAUlllCE S. RIEIZEH, M.O., Director Honorable Marcus A. Rowden Chairman U.S. Nuclear Regulatory Cammi ssion Washington, D. C.
. 20555
Dear Chairman Rowden:
January 2 7, 19 77 RE:
Docket 50-255 The need for increased nuclear spent fuel storage capacity is a national energy problem resulting from the present zero capacity for commercial fuel reprocessing and high level nuclear waste storage.
The fact that the problem exists is not to the credit of the fuel cycle management of a responsible federal agency-industrial complex.
The continued lack of a national plan to cope with the problem even on an interim basis while plans are made for long-term storage is a matter of public health, safety and environmental concern.
The undirected and unanalyzed interim solution of providing for additional storage capacity for spent fuel at the nuclear powered generating sites via the routes of license amendment applications *is subject to severe questioning.
Each site is evaluated only as an independent case.
This method,*in our opinion, cannot result in meaningful cost effectiveness or benefit risk studies.
The best interests of the public will not be served if this non-solution persists.
This department requests that the Energy Research and Development Administration address this problem before amendments to licenses are granted for increased fuel storage capacity.
An environmental impact statement may be required under the National Environmental Protectfon Act to evaluate the consequences of the management of large. quantities of spent fuel by storage above ground at many locations throughout the natiqn.
. I' As a matter of concern for this department, the 11Consumers Power Company Palisades Nuclear Generating Station Spent Fuel Pool Modification Descrip-*;
tion and Safety Analysis 11 and 11Environmental Impact Evaluation 11 do not'*
adequately address the issues raised by the added spent fuel storage capacity.
We raise the following questions for which we would appreciate answers:
- 1.
- What alternatives capacity at.Palisades Regulatory Commission
- Administration?
to the increased spent fuel storage are being considered by the U.S. Nuclear or the Energy Research and Development*
!Ir--
MICHIGAN The Great Lake State I
Honorable Marcus January 27
- EJ 7J
.2.
What are the benefit/risk ratios for each of the alternatives being considered by these agencies in terms of public health and environmental impact?
- 3.
The Report and the Environmental Impact Evaluation state that 11normally 11 only fuel decayed for at least one year will be stored in the Future Tilt Pit and the safety analyses are based on the 11 normal 11 condition.
Will storage of fuel that has decayed for less than one year be prohibited in the Future Tilt Pit? What assurance will be given to the U.S. Nuclear Regulatory Commission?
- 4.
A number of cooling alternatives are noted n.s backups to the primary Fuel Pool cooling source.
Would these cooling sources be available in the event of any accident, or could they be required for other essential plant functions, thus invalidating the temperature analyses?
- 5.
Section 6 of the Report states that cooling analyses treat the main pool and t~e tilt pool as one pool.
In view of the construc-tion of the pools, is this treatment :easonable? *
- 6.
Why do some of the analyses assume the presence of boron in the cooling water while others do not? Under what conditions would borpn be absent in the cooling water?
- 7.
Why has the possibility of blocked coolant flow through one or more fuel assemblies with attendant temperature rise.and fuel failure been omitted, especially in the Future Tilt Pit with its normally higher temperature? Would elevated temperatures adversely affect the boron carbide (B4C) plates?
- 8.
Have dose calculations been made assuming water loss in the poolsi 9..
Has the probability of a breach of pool integrity been consider-ed in view of the fuel tilt pit addition with a north wall thickness of only two feet?
10~ The Report describes the use of 11 detailed written procedures designed to preclude any possibility of dropping a rack on the stored fuel el ements 11 and control of crane movement "by written administrative procedures which will prohibit the movement of spent fuel racks or control rod racks directly over locations in the pool where fuel assemblies are being stored.
11 It is a matter of record for the Palisades Plant and other nuclear facilities that written administrative procedures do not "preclude" or "prohibit" anything.
Will the use of mechanical and/or electrical interlocks to control and limit the movement of the crane during rack installation be requ*i red?
f.lonorable Marcus A.
J~owden
- :l -
- 11. *What are the numerical increases in dose rate and actual projected doses for conoi ti,ons as related in Section 7 of the Report?
- 12.
Section 7 of the Report discusses the galli11a dose rate under the Cask Laydown Area of the Spent Fuel Pool.
Section 2 of the Environmental Impact Evaluation describes the pool as having 11 reinforced concrete walls and floor 4~ to 6 feet thick.
11 The concrete floor thickness in the Cask Laydown Area is only 2~ feet.
Likewise; the Tilt Pit floor contains 5 feet of concrete, compared with 6 feet for the main Spent Fuel Pool floor.
Have these thick-nesses been used *for the dose rate calculations?
- 13.
The Environmental Impact Evaluation notes that 3.4% of the annual United States consumption of BaC will be used.
Considering that Palisades is one of the many nuclear plants which may have this same need, 3.4% does not seem to be "only a small fraction" of this resource.. Should not other uses of B4C and the effect of total nuclear industry needs upon its availability for these uses be addressed?
- 14.
The accessability of nuclear materials could by skillful use of available explosives produce a public health and safety risk out of proportion to the benefits.
What additional security protection is proposed to prevent sabotage by a reactionary group or a disgruntled or deranged employee?
- 15.
Plans include the installation of a jib crane to facilitate Tilt Pit fuel handling.
No details are provided.
Will simultaneous Spent Fuel Pool and Tilt Pit fuel handling be allowed?
What portion of the Tilt Pit pool will the crane service? Will the crane be mobile?
Crane installation is planned for the north end of the Tilt Pit,.
which is adjacent to the alternate cask laydown area.
Has interfer-ence of the crane with cask and Fuel Handling Machine movement been
- considered?
Compared wi~h existing fuel handling and crane facili~ies, how will the probable reduced reliability of fuel handling by the jib crane affect the accident analysis?
- 16.
The number of fuel assemblies projected for the pool is not compatible with the stated refueling schedule.
What refueling schedule is the basis for the projection?
Your careful consideration of these issues before a decision is reached on Consumers Power Company license amendment is requested.
We empathize with the electrical power generating problems ar,d energy needs, but health and safety must not be compromised.
Honorable Marcus January 27, 1977 Tharik you for your cooperation in the protection of the pubii c heal th and safety of Michigan's residents.
Sincerely, M.D.
I I I 1*
I l i I 1* i i
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In the Hatter of UNITED STATES OF A!*:ERICA NUCLEAR REGULATORY co~~lISSIO~
CONSUHERS POWER CCA*1PANY
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Docket No. (s)
(Paiisades Plant)
CERTIFICATE OF SERVICE 50-255 I hereby certify that I have this day served the foregoing docu~ent(s) upon each person designated on the official service list co~pilcd by the Office of the Secretary of the Cor.nission in this proceeding in accordnnce with the requirc:::ents of Section 2. 712 of 10 CTR Part 2 -
Rules of Practice, of the Nuclear.Regulatory Cor.~uission's Rules and Regu] at ions..
Dated at Washington, D.C. this
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197.1_
- Office of the Sccret~ry o he Corrl!l.iss ion
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UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION In the Matter of CONSUMERS POWER COMPANY (Palisades Plant)
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- .SERVICE LIST Samuel W. Jensch, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.. 20555 Dr. David B. Hall Los Alamos Scientific Laboratory P.0 *. Box 1663 Los Alamos, New Mexico 87544 Docket No.s(s) 50-255 Mr. Jerry Sarno Township Supervisor Route 1, Box 10 Covert, Michigan 49043 Eric V. Brown, Sr., Esq.
Brown, Colman & DeMent 125 West Walnut Street Kalamazoo, Michigan 49007
- Office of the Executive Legal Director Mr. Ron McCandlis Counsel for NRC Staff 5619 Clato U.S.Nuclear Regulatory Commission Washington, D.C.
20555 George F. Trowbridge, Esq.
Shaw*, Pittman, Potts & Trowbridge 1800 "M" Street, N.W.
Washington, D.C.
20036 Judd L. Bacon, Esq.
Legal Department Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 43921 Marvin F. Metge, Esq.
Gorham, Adams, White & DeYoung One North LaSalle Street Chicago, Illinois 60602 Honorable Jerome Maslowski Assistant Attorney General State of Michigan Lansing, Michigan 48902 Honorable Curtis G. Beck Assistant Attorney General State of Michigan Lansing, Michigan 48913 Kalamazoo, Michigan 49004 Joseph T. Sobota, M.D.
2312 Glenwood Drive Kalamazoo, Michigan 49001 Lewis D. Drain, Esq.
Miles, Mike, Meyers, Beckett and Jones Waters Building, Suite 311*
Grand Rapids, Michigan. 49052 Myron M. Cherry, Esq.
One IBM.Plaza Suite 4501 Chicago, Illinois 60602 Harold P. Graves, Esq.
Vice President and General Counsel*
Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 O.K. Peters~n, Esq; Senior Attorney Consumers Po_wer Company 212 West Michigan Avenue Jackson, Michigan 49201
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