ML18347B265

Petition for Leave to Intervene

ML18347B265
Person / Time
Site:	Palisades  (DPR-020)
Issue date:	02/27/1979
From:	Sinclair M Great Lakes Energy Alliance
To:	Atomic Safety and Licensing Board Panel
References
Download: ML18347B265 (10)

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7\\1~111-UNITED STATES OF M-tERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of Consumers Power Co.

Palisades Nuclear Plant South Haven, Michigan

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.... 1 D!>cket No.50-255SV PETITION FOR LEAVE TO INTERVENE Pursuant to the notice of hearing on the intention of Consumers Power Company to shut down the Palisades Plant in 1981 in order to replace defective steam generators, the Great Lakes Energy Alliance, an unincorporated association of citizens' groups in the State of Michigan, hereby petitions for leave to intervene in the above proceedings before the Nuclear Regulatory Commission.

IDENTIFICATION OF PETITIONER AND INTEREST A)

The Great Lakes Energy Alliance is an unincorporated association of citizens' groups which has formed in the State of Michigan and the Great Lakes area to study energy problems and policies and to disseminate information and stimulate pub-lic awareness and involvement in the study of nuclear power and safe energy alternatives.

B)

Many citizens belonging to several member organiza-tions of the Great Lakes Energy Alliance reside in close prox-imity to the Palisades nuclear plant at which the repair on defective steam generators allegedly will take place.

Among these groups are the Coho Alliance of St. Joseph, Michigan, United for Survival at Benton Harbor, Michigan, and the Grand Haven Alliance of Grand Rapids, Michigan.

These groups have a special concern in regard to the environmental and social impact of the replacement of defective steam generators which E*the subject of this licensing proceeding.

C)

Fifteen of the total of twenty-two citizens' groups from Michigan and Illinois who comprise the Great Lakes Energy Alliance (hereafter referred to as "Petitioners") are ratepayers of Consumers Power Company and therefore have a special economic as well as social and environmental interest in the replacement of defective steam generators which is the subject of this licensing proceeding.

STATEMENT OF CONTENTIONS

1)

The shutting down of the Palisades nuclear plant to replace defective generators will require exposing workmen to hazardous levels of radiation. *Recently, studies have shown that the radiation standards that have been purported to be safe for workers in nuclear installations have resulted in a higher in-cidente of cancer among those workmen than in a comparable group in the general population.

The NRC is now proposing more conservative radiation standards for workmen.

The Petitioners want to know how adequate protection from radiation hazards will be given to the workmen involved in this project.

2)

The defective steam generators that must be re-placed will be contaminated with radioactivity.

The Petitioners want to know the nature and extent of the environmental and safety review procedure which the NRC will undertake to protect the public during the repair operations.

3)

Petitioners-want to know the type of procedure which will be employed for replacement of the steam generators.

4)

The defective steam generators constitute a type of long-lived, toxic radioactive waste which will have to be stored and disposed of permanently.

The Petitioners want to know what plans are being made for disposal of this defective equipment.

5)

The Michigan Legislature has passed a bill banning the disposal of nuclear waste in the State of Michigan.

In view of this law, Petitioners want to know where the defective and radioactive contaminated steam generators will be shipped for storage, since it cannot be stored in this State, and what routes for its transportation in the State will be used.

6)

Petitioners want to know the environmental and safety risks that are associated with the long-term storage and/

or disposal of these defective radioactive parts of the Palisades n-plant.

7) It has been reported that replacement of defective steam generators can take approximately two years' time and can cost a quarter of a billion dollars.

(See Exhibit A, attached.)

Petitioners want to know who will pay for the power that will be purchased during that period of time and who will pay for the new steam generators and the labor and supervision involved.

8) Petitioners want to know what the cost of the per-manent storage of the defective radioactive parts will be and who will pay those costs.

9)

Petitioners want to know how this type of problem can be prevented from reoccurring in the other nuclear plants that Consumers Power Co. has under construction and is contem-plating for future construction.

VERIFICATION I, Mary P. Sinclair, am a duly authorized spokesperson for the Petitioner, the Great Lakes Energy Alliance.

As such, I have drafted the foregoing Petition to Intervene, and affirm that all statements made therein are true to the best of my knowledge and belief.

I am authorized to sign this petition and make this af firmation on behalf of the above named ~etitioner.

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I Date Subscribed and sworn to_ before me this 27th day of February, 1979.

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Veronica L. Winslow Notary Public Midland County, Michigan My Cornn. exp: 11/14/81

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By M1"'E TONi::R _....

Knight-Ridder NcwsPallers

• • c6rros!on:.. cracks~ '.d~nts.

11-nd leaks are slowly crippling a gro~ving numbet* of the

• country's nuclear power*

plants...

, The wave~ of.. unforeseen'.

prob rems, so far detected in at*

• least 20 U.S. piants, threatens the nucleur industry, and ulti-in:itcly itl customers, with a rep:ilr-bill already calcufated in tho-hundreds of millions of

~olla..--s. * * ~ * -..

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• - ___ J UPI Pholo Atleasttwoplants.;._Flor- -

ida Power & Light Co.'s Tur-key Point reactors and Vir-ginia,Electric Power Co.'s.

Surry nuclear station -

are 1

• scheduled to.be shut next year

• for massive overhauls. There*

are growing feara that other plants..:.may.face similar prob-Cracks wero found in 1975 in this nuclear power plant in Morris, Ill., and it becama one of many to ba shut down for inspection.

lems.-*..

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When the Turkey Point 1 1

work is finished after two years;- the. repair bill -

in-cluding an* estimated $150 million in increased fuel costs

• that Florida ?ower & Light customers may have to pay while the plant.is out o! serv-ice ~: is expected to total more th;in a quarter of a bil*

lion dollars.'

. Tifat'saboutwhatitcostto' build the plant in 1972.

IN ADDITiON tG the un-

• precedented cost of repairs, the cieterioration of the plants' '.

steam 3e11erators is responsi~

ble far:

o Nu-merous reactor shut-*

downs,..often in. the midst of peak demand periods, to pre-vent any leakage of radiation outside the plant and to assure

• its safe operation in the event o1 an accident.

nuclear power plants ln the United States, but they are

• most severe at the Surry sta-tion in northern. Vir?inia and the Turkey Point plant in*

southern Dade County.

The problems -

cracks and dents in the bun'dles of slender tubes in the plants' steam. generators -

are less severe in the other plants. But they* have stirred growing

!ears in the indust..-y that thei:

overhauls at Surry and Tu;-

• key_ Po.int may be-merely the begmnmg of a wave ot reoairs '

that the country's current '

generatiOO"Of r,eactOrS' Will~

face..-

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~p~y. NEXT yea!', the; whitc.*domed Surry station..

~arely out of its infancy as the life expectancy of such instal-liltions is figured, will begin

• under3oing S50 million worth of,repairs-. The increased cost oi oil and go.s to generate re.

placement power will cost the company and its customers i' about $250,000 a day...

Repairs are expected to- \\

& Sporadic* outages for re-.' b~gin at Turkey Point a few pairs *that may require ex-months later.

• scn1y deposit, dubbed "green srunge" by engineers.

Tne*material builds up in the plants' steam oenerators the portion of the 0 plant that ;

converts the heat of its nu-.'

clear chain reaction into steam; Both utilities.tentatively have decided. that only the.

complete replacement of the*

plants'* deteriorating steam.

generators, originally ex-

• pected to last for the full 40-year life of the reactors, will

-enable them to continue to run at full power.

• . Both utilities are openly

.*dismayed at the prospect.

The Florida utility was so ;

sure that.the steam generators

. w~uld last. when the Turkey.

Point plant was buiit that they.

were permanently installed.

They will literally have to be torn out of their concrete and steel support:>.

. ** nm COMP ANY has sued the Westinghouse Electric Corp., which supplied the steam generators tor Turkey Point.as well as most of the other nuclear. power plants in the country.

tended. sl:.utdowns*and' often After only six years of op-expose power plant workers eration, both plants are suf-to incie::isetl radiation.

fering from a rapid accumula-So far.. the corrosion-re-: tion of corrosion-related lated problems* have been defects, most ot them trace-

• toundat20ofthe46operati~g abl~ to_ the growth ot a tough, "A lot of people are upset,"

says John T. Benton the

_firm's supervisor of n~clear engineering. "You'd be upset

• too if you bought a new car and it broke down after a day's driving."

Even many of the power plants now free of corrosion may not be immune for long. -

. Some have been in service. for i *only a-year or two.

"It appears to be only a matter ot time until a unit experiences problems," says

_John Mudis, who helps co-ordinate a S40 million re-search program on the matter for the electric Power Re*

search. Institute.

. "Unless appropriate cor-rective actions are taken, all pressurized water reactors face a significant probability of steam generator replace-ment prior to the end of the.

40-year plant life time," he '.

warns.

.

• CHEMICAL and mechani-

..E,al cleaning shows some sign::;.

"'of easing the accumulation of

• *~green grunge" but early signs of deterioration have ap-peared at some units after less

• than two years of operation.

_"I~ _a, very '.1'1desp!ead problem," agrees Darrell G Eisenhut, assistant director ot the U.~.. Nuclear Regulatory Comm1ss1on's division of op-erating reactors.

Steam supply systems of

all three major U.S.. manufac*

is nothing safer than a nuciear The leaks may also in*

turers, Westinghouse, Bab*

power plant tl'iat is shut crease the chances that opera.-

cock & Wilcox and Combus-down," says David Corney, tion of the plant's safety sys-tion Engineering, have expe-president of the Chicago* terns will be Im.paired in the rienced problems. * -

based Citizens for a Better event oi a major reactor acci* :

'* _ But the wi4ening scope of

• Environment.

. dent..

the problem poses more than a "If the steam' generators No stea.."n generator leaks mere technical headache* for. : continue to.corrode, there will have ever released radioactiv-the industry. It also threatens *be no better incentive for-not ** ity that exceeded legal limits

• its public image.

building a nuclearpiant in the or. interfered with the plants' "We.have to eliminate the first place, he says~*-

• *.. _safety systems.

occurrence of corrosion," _ex* -

• Even though the extended*.*

ONE "'Ji! ARTICULA.RL Y be* :

plains.*Tom Anderson, man** overhauls. at Surry aud Tur**. leaguered power plant. :Miclli*

ager of the nuclear safety de*

key Point haven't begun, gun's Consumers Power Co.'s partment for Westinghouse.

• steam gemmi.torproblemsare.. Palisades unit, has been.shut "We can't just go out whole*

already a major contributer to. down more in its seven yea:r'ir sale and replace steam geuer*

nucle!Z' power plant outages cf operation than it has b'een

• ators; that would undermine: throughout the country.

in-service.

public confidence."

The most minute leak in The company says that

• NUCLEAR CRITICS al;,;

ready have seized on the situa-

-* tiori as 0 the Acnilles' heel" of the coun~y's commercia11 nu*

clear power program.

"Our position is that there *

• any of the t.iousands of slen* * "improper design and manu- ;

der tubes bundled together in* facture." of the plant's steam.

side the steam generator indi;.

generators has been a major rectly results in some increase reason that it has been able to of rarliooctivity released i:nto operate at only about one*

the environment around the. third cf its potential capacii:"J.

plant..

since it went into service in l

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1971.

So far the company h;;.;s~

• collected $40.5 million in out-**

ofQcourt settlements froL.'1.

Cc1nbustion Enginserinr;, the*

company that furnished the steam suppiy system for th'.::.

• plant.

Pul!sad£:s is currently O\\)"*

• crating at n\\":ar!y full pow~;*.:.

but its probli.:ms arem't ov,:~:.

Compa.uy offici~1s-say t~... ).**

• buildup of corrosion secm::;;*r:;*

have slowed, *out the d:;.;-n~~=~*

• is already so ;;xteuslv0 t'.,::';, :

they plant to close it down 1_<:

1982 for "nlt2jor steam gcn!2r~

• ator n:odificatioiu.'.'.

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UNITED STATES OF AMERICA

NUCLEAR REGULATO~Y COMMISSION

[Docket No. 50-?55-SP]

CONSUMERS POWER CO..

ABLISHMENT* OF ATOMIC SAFETY AND LICENSING BOARD TO PRESIDE IN PROCEEDING Pursuant to delegation by the Commission. *dated December 29, 1972, published in the Federal Register (37 F.R. 28710) and Sections 2.105, 2.700, 2.702, 2.714, 2.714a, 2.717 and 2.721 of the Commission's Regulations, all as amended, an Atomic Safety and Licensing Board.is being established in the following proceeding to rule on petitions for leave to intervene and/or requests for hearing and to preside over the proceeding in the event

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that a hearing is ordered.

CONSUMERS POWER CO.

(Palisades Nuclear Plant)

Provisional Operating License No. DPR-20 This action is in reference to a notice published by the Commission on January 29, 1979, in the Federal Register (44 F. R. 5732) *entitled "Propos~d Issuance of Amendment to Provisional Operating License".

The Chairman of this Board and his address is as follows:

Charles Bechhoefer, Esq.

Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Palisades 2 -

The other members of the Board and their addresses are as follows:

Dr. George C. Anderson D~p~rtment of Oceanography University of Washington Seattle, Washington 981~~

Dr. M. Stanley.Livingston 1005 Calle Largo Santa Fe, New Mexico 87501 4-~/F.~

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c7 James R. Yore: Chairman Atomic Safety and Licensing Board Panel Dated at Bethesda, Maryland this 9th day of March 1979.

u In the Matter of UNITED ST.ATES OF AMERICA NUCLEAR REGuLATORY CO~fMISSION

• co:::-;srnlERS POl-!ER CO~lPAfIT

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Docket No. (s)50-25SSP (Palisades Nuclear Plant)

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CERTIFICATE OF. SERVICE.

I hereby certify that I have this day served the foregoing docuwent(s) upon each person designated on the official s_ervice list. compiled by the Office of the Secretary of the Commission in this proceeding in accordance with the.requirements of Section 2. 712 of 10 CFR Part 2 -

Rules of Practice, of the Nuclear Regulatory Col:!Elission's Rules and Regulations.

Dated at Washington, D.C. this 1.'.-17 t;"_ !)

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. Offic*e.b~! the Secretary of th~ Commission d- ); ',;Jt:;.J,..-ic...c..tk1,./...u.f dl!c.. 3/1 /17

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-e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of CONSUMERS POWER COHPANU (Palisades Nuclear Plant)

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SERVICE LIST

-Charles Bechhoefer, Esq., Chairma~

Atomic Safety and Licensing Board

-U.S. Nuclear Regulatory Commission Washington, D.C.

20555_

Dr. George C. Anderson Department of Oceanography

-University of Washington Seattle, Washington 98195 Dr. M. Stanley Livingston 1005 Calle Largo Santa Fe, New Mexico 87501 Counsel for NRG Staff Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Docket No.(s)50-255SP 1*f. I. Hiller, Esq.

Isham, Lincoln & Beale One First National Plaza, Suite. 4200 Chicago; Illinois 60670 Hs. 1::fary P. Sinclair Great Lakes Energy Alliance 5711 Summerset Drive Midland, H1chigan 48640