ML18347B265

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Petition for Leave to Intervene
ML18347B265
Person / Time
Site: Palisades Entergy icon.png
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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Text

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7\1~111-UNITED STATES OF M-tERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board SERVED rv~AR l 1° LJ ~q7!'.1

, .., * ....1 In the Matter of )

Consumers Power Co. ) D!>cket No.50-255SV

)

Palisades Nuclear Plant )

South Haven, Michigan )

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.

~- ~7" *1r f zrI 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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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 ':\i'.~1+'.:'.:t1 21:t1 in tho-hundreds of millions of

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

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

ida Power & Light Co.'s Tur- Cracks wero found in 1975 in this nuclear power plant in Morris, Ill., and it becama one key Point reactors and Vir- of many to ba shut down for inspection.

ginia ,Electric Power Co.'s .

Surry nuclear station - are 1

  • nuclear power plants ln the scheduled to.be shut next year
  • United States, but they are
  • scn1y deposit, dubbed "green too if you bought a new car for massive overhauls. There* most severe at the Surry sta- srunge" by engineers. and it broke down after a are growing feara that other tion in northern. Vir?inia and Tne*material builds up in day's driving."

plants..:.may.face similar prob- the Turkey Point plant in* the plants' steam 0oenerators Even many of the power lems.-* .. . . \ southern Dade County.

  • the portion of the plant that ; plants now free of corrosion When the Turkey Point 1 The problems - cracks converts the heat of its nu- .' may not be immune for long. -

work is finished after two 1 and dents in the bun'dles of clear chain reaction into i .*only Some have been in service. for a- year or two.

years;- the. repair bill - in- slender tubes in the plants' steam; cluding an* estimated $150 steam. generators - are less - Both utilities.tentatively "It appears to be only a million in increased fuel costs severe in the other plants. But have decided .that only the . matter ot time until a unit

  • that Florida ?ower & Light they* have stirred growing complete replacement of the* experiences problems," says customers may have to pay !ears in the indust..-y that thei: plants'* deteriorating steam . _John Mudis, who helps co-while the plant.is out o! serv- overhauls at Surry and Tu;-
  • generators, originally ex-
  • ordinate a S40 million re-ice ~: is expected to total key_ Po.int may be-merely the pected to last for the full 40- search program on the matter more th;in a quarter of a bil* begmnmg of a wave ot reoairs ' year life of the reactors, will for the electric Power Re*

lion dollars.' that the country's current ' -enable them to continue to run search. Institute.

generatiOO"Of r,eactOrS' Will~ at full power. ."Unless appropriate cor-

. Tifat'saboutwhatitcostto' face.

build the plant in 1972.

~p~y.

NEXT yea!',

the;

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  • . Both utilities

.*dismayed at the prospect.

are openly rective actions are taken, all pressurized water reactors The Florida utility was so ; face a significant probability IN ADDITiON tG the un-

  • sure that.the steam generators of steam generator replace-precedented cost of repairs, whitc.*domed Surry station. . . w~uld last. when the Turkey . ment prior to the end of the .

the cieterioration of the plants' '. ~arely out of its infancy as the Point plant was buiit that they . 40-year plant life time," he '.

steam 3e11erators is responsi~ life expectancy of such instal- were permanently installed. warns.

ble far: * * : * : :.

  • liltions is figured, will begin
  • They will literally have to be under3oing S50 million worth .
  • CHEMICAL and mechani-o Nu-merous reactor shut-* of,repairs-. The increased cost torn out of their concrete and :..E,al cleaning shows some sign::; .

downs,..often in. the midst of oi oil and go.s to generate re. steel support:>.

  • peak demand periods, to pre- placement power will cost the . ** nm COMPANY has sued "'of easing the accumulation of
  • *~green grunge" but early vent any leakage of radiation company and its customers i' the Westinghouse Electric signs of deterioration have ap-outside the plant and to assure
  • about $250,000 a day... Corp., which supplied the peared at some units after less
  • its safe operation in the event Repairs are expected to- \ steam generators tor Turkey than two years of operation.

o1 an accident. Point .as well as most of the _"I~ _a, very '.1'1desp!ead

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

  • the country. problem," agrees Darrell G tended. sl:.utdowns*and' often After only six years of op- "A lot of people are upset," Eisenhut, assistant director ot expose power plant workers eration, both plants are suf- says John T. Benton the the U.~ ..Nuclear Regulatory to incie::isetl radiation. fering from a rapid accumula- _firm's supervisor of n~clear Comm1ss1on's division of op-So far.. the corrosion-re-: tion of corrosion-related engineering. "You'd be upset
  • erating reactors.
  • lated problems* have been defects, most ot them trace- Steam supply systems of
  • toundat20ofthe46operati~g abl~ to_ the growth ot a tough,

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all three major U.S .. manufac* is nothing safer than a nuciear The leaks may also in* 1971.

turers, Westinghouse, Bab* power plant tl'iat is shut crease the chances that opera.- So far the company h;;.;s~

  • cock & Wilcox and Combus- down," says David Corney, tion of the plant's safety sys- collected $40.5 million in out-**

tion Engineering, have expe- president of the Chicago* terns will be Im.paired in the ofQcourt settlements froL.'1.

rienced problems. *- based Citizens for a Better event oi a major reactor acci* : Cc1nbustion Enginserinr;, the*

'* _ But the wi4ening scope of

  • Environment. ., . dent. . ** *
  • company that furnished the the problem poses more than a "If the steam' generators steam suppiy system for th'.::.

No stea.."n generator leaks *plant.

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 Pul!sad£:s is currently O\)"* *

  • its public image. building a nuclearpiant in the or. interfered with the plants' crating at n\":ar!y full pow~;*.:.

"We.have to eliminate the first place, he says~*- * *.. _safety systems. but its probli.:ms arem't ov,:~:.

occurrence of corrosion," _ex* -

  • Even though the extended*.* ONE "'Ji! ARTICULA.RLY be* : *buildup Compa.uy offici~1s- say t~ ...).**

of corrosion secm::;;*r:;*

plains.*Tom Anderson, man** overhauls. at Surry aud Tur**. leaguered power plant. :Miclli* have slowed, *out the d:;.;-n~~=~*

ager of the nuclear safety de* key Point haven't begun, gun's Consumers Power Co.'s *is already so ;;xteuslv0 t'.,::';, :

partment for Westinghouse.

  • steam gemmi.torproblemsare ..Palisades unit, has been.shut they plant to close it down 1_<:

"We can't just go out whole* already a major contributer to . down more in its seven yea:r'ir 1982 for "nlt2jor steam gcn!2r~

  • sale and replace steam geuer* nucle!Z' power plant outages cf operation than it has b'een
  • ator n:odificatioiu.'.' . .~;;:..:;;

ators; that would undermine: throughout the country. in-service. ..*.~

public confidence." . The most minute leak in The company says that *

... NUCLEAR CRITICS al;,; *any of the t.iousands of slen* * "improper design and manu- ;

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

ready have seized on the situa- side the steam generator indi;. generators has been a major

-*tiori as 0 the Acnilles' heel" of rectly results in some increase reason that it has been able to the coun~y's commercia11nu* of rarliooctivity released i:nto operate at only about one*

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

"Our position is that there

  • plant. . since it went into service in l

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

~

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

- 2 -

Palisades 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.~

~ c7 ..

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

u

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

)

co:::-;srnlERS POl-!ER CO~lPAfIT ) Docket No. (s)50-25SSP

)

(Palisades Nuclear Plant) )

.)

)

)

)

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;"_!)

'-/~,/_..,___day of (Jn /1 / ._,..,

  • J!u:/'- /' J,,,

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. Offic*e .b~! the Secretary of th~ Commission

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~ . -e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

CONSUMERS POWER COHPANU ) Docket No.(s)50-255SP

)

(Palisades Nuclear Plant) )

)

)

SERVICE LIST

- Charles Bechhoefer, Esq., Chairma~ 1*f. I. Hiller, Esq.

Atomic Safety and Licensing Board Isham, Lincoln & Beale

-U.S. Nuclear Regulatory Commission One First National Plaza, Suite. 4200 Washington, D.C. 20555_ Chicago; Illinois 60670 Dr. George C. Anderson Hs. 1::fary P. Sinclair Department of Oceanography Great Lakes Energy Alliance

-University of Washington 5711 Summerset Drive Seattle, Washington 98195 Midland, H1chigan 48640 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

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