ML19029A454
| ML19029A454 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/26/1979 |
| From: | Onsdorff K, Van Ness S - No Known Affiliation |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML19029A454 (30) | |
Text
. U\ITED STATES OF N\ERICA NUCLEAR REGULATORY CG.{*!ISSIO\"
In the Matter of )
)
FUBLIC Sf:R\'ICE ELECTRIC *E1 GAS ) Docket No. 50-272 CC;\,lPXN, et al., ) (Proposed Issuance of Arn.enc1r:i.ent
) to Facility Operating License (SJ.lem Nuclear G2nerating Station, ) No. DPR-70)
Unit 1) )
10rruzvENORS, coLH L:\.\JS 1 , ~lErt!:"JR'-\:':rnJM IN OPPosr1ro~I TO TilE LICE);SEE 'S ;.;cir rm; FOR SlJ?-aL\J<.Y DISPOSITION INTER'v'ENORS' STATHiE?\T OF H\TERIAL FACTS V~ DISPUTE PI.JffAINH~G TO CO~iTE\JTTON T\\'O.
- 2. The licensee has given in:1dequate co0~s*i.deration to the occurrence of. accident1l criticality dw~ to the increa.sed dcn::;ity or coi:1~).Jction of tl1e. spent. fuel assemblies. J\.cldi tional considerc1tion of cri tie:~li ty is required clue to the folJ.o\*:ing:
A. deteri oratio!l of the neutron absorbtioll material provided by the Boral plates locat,::J between tlle spe.nt fuel bundles; B. deterioration of the rJ.ck st11tcturc leading to failure of the rack ~md consequent dislodging of spent fuel !:n.mdlcs.
For its convenience, P. S. [. &G. hos chooscn to lump together its c::,n.sidcration of the ColeI:taJ1s r Contentions Ti*:a OT Six. TIH~se separate safety
- i.:=;sues, hrn*:cver, a:re too inmortant to be glossc'cl mrcr 1-:itJ1 such superficial t:r-c'at:ncnt. The Colemans' second content.ion ck:~ds dirccth* \*Ji th the in:.:rca:;ed pot6:1L:iaL of accic.lcntial cdtic:tlit:: occurri.r1g in the: snent fucJ. pool :..~1.to:~ to
- .::~ich 2.re proposed to be placed s i gni ficcmtl:-* closer than rn previo1.E !.ong t*~.'llTI usage in the nuclear industry.* Accordingly, the statement on the sixth p<Lge of licensee 1 s memorandu!l in supnort of its motion, to wit: 11 ur1irradicated
- ~tainless steel fixtures have been e:x.1Josed in pools up to 20 years and Zircµloy clad spent fuel has been successfully s toTed in pool for up to 18 years without evidence of degradation," is a complete . -- __ __
non sequitur.
Intervenors in this proceeding are not op\)osing storage of spent fuel in Hater cooled basins situated adjacent to a nuclear generating station situated near the Philadelphia metropoli tai'1 area. Rather, they are strenuously objecting to the density of such Lmnrecedented long tenn basin storage at this .
location with an W1tried system ~hat entails a known potential for rack d.:::terioration.** In this case, past experience 1~*it..1. lo;v density storage provides Yery little assunmce of high density pool safety.
Furthennore, what experience there has been wi-th spent fuel pool storage in conjlmction with nuclear power plant 011erations is not reassuring. As stated in foe f.!inor affida1.ri t attached hereto the Monticello and Connecticut Yankee reactors c::-.-perienced rack degradation. (Minor, page 3,B). The relevance of these rack intcgri ty deficiencies, 1vhile disputed by P. S .E. &G. , is clearly <:m unresolved factual i~.sue material to the Colemans' contention uvo.
Finally, the very report relied upon the licensee: "Behavior of Spent Nuclear Fuel in Water Pool Storage," BN\\11-2256 Battelle ~forth\<iest Laboratories, Scotcrnber 1977~** details the b1own corrosion problcii1S *uhich have
- ~"The present rack design has a nominal center-to-center spacing between fuel storage cavities of 21 ind1es. The proposed new snent fuel racks 1.;ould be c:odular stainless stcll structures with individual storage cavities to prm:ide a nominal ~
center-to-center spacing of 10.S inches." NRC S.taff Safety Evaluation, January 15, l~I 79 Section 1. 0, page 1-1, paragr.'.l!Jh 2.
- ~:~This \RC Safety and Licensing So.'.lrd cm take judicial notice of the fact th.'.lt heat plus acidic water over tine in1.luces corrosion in metal::;, incluG.i.;1g stainless steel. 'foe :\'RC Staff Safety cval ua ti on es tin1a tes that: "The r:1c.L>cirn!.rrn inCJ.*c1ren tal heat loads that will be added by increasing the nurriber of spent fuel 2Sscnblic:>
in the SFP from 264 to 1170 will be 4.S x 106 Btu/hr." Report page 2-4, Section 2 . 2. 2, paragraph Two. .
- '=Since P.S.E.c1G.'s motion and supporting docuoents att.:1.ched thereto only the first four pages of the Battelle Report, page thirty-six of this report is attachc*l here-to as Exhibit A.
alre:idy occurred in spent fuel pool storage cells:
11 Alurainu:n corrosion behavior has been subst.:mdarcl in some borelted. pools. . . . Considerable alrn-:-..:i.num corrosion also occurred in crevices on the cannisters, perhaps due to oxygen concentration cells."
The unfortunate circlll11stance that .the Battelle Reoort cJ.n only speculate on the cause of the corrosion as being the result of oxygen concentration cells merely adds to the unresolved safety issues pertaining to long term basin s tor2ge.
Intervenors intend to fully examine both the :NRC and P.S.E.&G. witnesses concen1-
. ing these corrosion risks at the Salem hearings in Jlhy.
1(-ffER\/E\ORS I STATEME1\"T OF H\TERL-'\L FACTS l\ DISPUT[ PERTAINI:\JG TO CO\TE'H'ION SIX
- 6. The licensee has given inadequate consideration to qualification and testing of Bora.l m<l.teria.l in the envirornnent of protracted association \v"ith spent nuclear fuel, in order to validate its continued properties for reactivity control and integrity.
The m::merous illlresolvecl safety issues nertaining to -::his contention are bc.:st exemplified by the licensee's anomalous argm:tent that the greatest care possible has been taken to protect the Boral fron exposure to the spent fuel pool 1:ater envirorunen; h'hile proposing under certain circumstances to dose this Baral with contaminated pool water. When a leaking problem arises in ti.lie stainless steel shroud, P .S .E. &G. intends to drill vent holes in til-ie top of the storage G::ll to relieve the gas pressure buildup inside. TI1is intentional bTead1ing of the integrity of the Boral protective shielding demands the utmost scrutiny to determine all the consequences of nction which, on its face> appears to severely tmdermine t.h.e very design basis for the safety 3nalysis of the spent fuel pool.
Ixm:lplcs of specific factual questions pertaining to the nature of this venting procedure abotmd: what equipment will be usecl to drill these vent holes?, \~hat size holes aTe contemplated?, how long will the cells be used with vent holes?.
\*,1Jat safeguards Hill be used to ensure that the holes are drilled no further th2.n required to relieve the gas pressure buildl.t'P? In sum, no detail is gi YC!'..
on the proposed meti'10d of relieving the gas pressure thru venting without doir"g
<:tcldi tional dmnage to this safety system.
Moreover, the uncertainties of so-called norr.1al storage ope.rations are also fertile areas for factual inquiry b)' this Board. P .S.E. ~G. has stated that its p-resent NRC plant oper2~tion license pcrmi 's continuous use of the spent fuel pool for the life of the plant, a.p!1roximatcly 40 years tine; also use beyonJ this period is even. contemplated (See Transcript, Prehearing Conference, May lS, 19 78;
'1'62-16 to T63-6. Despite this very real possibility that fuel asseT!lblies will be kept in the Salem pools* at least for se-\..-enteen years (due solely to econonic considerations since viable alternatives now e:x:i.st), the NRC Staff Safety Rei:ort states:
"Since the possibility of long-ten11 storage of spent fuel exists, the effects of the pool environment on the racks, fuel cladding and pool liner are uncler continued investigation."
- NRC Staff Safety Evaluation page 2-14, Section 2.4.1, paragraph Two.
111is candid acknowledgement by Staff that the P.S.E.&G. plan involves nany facets still being evaluated itself underscores the necessity of e:x3ffii.ning these issues at a plenary hearing prior to authorizing reracking *which may c:d>ose the public Lmknowingly to rnueasono.ble risks.
INTERVE:\'ORS' STATE~fENT OF MATERIM, FACTS IN DISPUTE PERTAL\:I?-!G TO COTENTIO:-.J l'!P:E
- 9. Tne Licensee has given inadel1uate consideration to alternatives to the proposed action. In particular, the Licensee has not adequately evaluated altematives associated with the Nuclear Regulatory Commission adopting the "no action" al terna ti ve for licensee's application, *whid1 would implicate b.i.e following:
A. expan5ion of spent fuel storage capacity at reprocessing plants; B. licensing of independent spent fuel storage installations; C. storage of spent fuel from Salem No. 1 at the pools of other reactors ;
D. ordering the generation of spent fuel to be stopped or restricted (leading to the slow-down or tennination of nuclear power production W1til ultimate disposition can be effectuated).
That material facts exist.concerning alternatives to the proposed. risky ex;-iansion of the Salem One and Two Spent Fuel Pools can not be seriously questioned.
?\or has P.S.E.f;.G. really attempted to do so. In its Statement of Undisputed Facts, F.S.E.&.G. has included the following points:
- 34. It is highly tmlikely that ai"L Indenendent Spent Fuel Storage Installation ("ISFSI") could be available to accept fuel by 1983 or 19S4. (euphJ.Sis add8cl).
- 36. It is unlikely that the Hope Creek lIDits ,.;ould be suffic.Lently complete to enable fuel to be stored prior to the unmodified Salem W1it fuel pool being fuel. (emphasis added) .
Of course, were this Board to deny Public Sencice 1 s application to e:...-pand its Salem Pools for any one o:f the safety or cn\*-j TOiu"'"Bnt3.l concerns addressed herein, we can rest assured that. the likclihooJ of the compmi.y e::...1;e:diting the:
construct.ion schedule foT th; Hope Creek pools \vould undoubtedly be E"iuch greater.
This is particularly so in light cf the cost of shut ting dovrn Salem One, estimated by P.S.E.*S.G. at $300,000.00 per day.
Furthermore, the unsettled posture of "ISFSin availability is S'..1bject to rapid change. Within this past week, the New York Times reported that the United States Department of Energy had reached 211 agreement in principle *with the State of New York regarding the reopening of the \\'est Valley, New York spent fuel storage facility. (N. Y. Tir.1es, p. 1, Mard1 21, 1979, E:x:i"ii.ibit B). :Jo one can make the categorical statement that an ISFSI *will not be available bv the time that Salen One and Two Hill reach IJQOl capacity (no sooner than late 19R'.) if no lll1usual drnm time is eA.])erienced at either plant; a highly tmlikely eventuality).*
To do so is pure speculation, upon whid1 a motion for slrrrnnary disposition can not b*~ grnJ1tecl. Mississippi Power and Light Company (Gra.11d Gulf Nuclear Station, Units 1 and 2), ALAB-130, 6 AEC 423, 424-425 (1973).
- ~111e NRC Staff Environmental Impact Ap;iraisal, January :LS, 1979:, Section 7~3 pJ.ge J 6, paragraph 3 states that the U.S. Departm.ent of Inergy annotmced in October of 1977 its plan to provide interim fuel storage facilities by 1983 or 1984-. *
- For some une>.--plained reason, the staff has decided to discount the avm-;ed comni t-ment of a Cabini:;t level Department of foe United States Government. 111is c:d. i \-Ber treatment of a major national initiative h'a:rr2s1ts a thorough review at a plefury
}1ea1~ir1g.
- <orcover, P.S.E.&G. has stated witJ10ut clarification that : 11 (s)ince Se:~lcE1 Unit 2 is e.x-pectecl to begin operation shortly ,L.Salem One has been operating for ovor 1 year now and 1vill need to refuel wi tJ1in a few 1,*cek-._j and. will h;:ive an arm.ti;:t1 discharge of fuel, both unenlarp;ecl fuel !1oob \*:ould be full by 1983 even :if the c1paci ty of the pools were shJ.red jointly." This identical dsadline for both nl:.m ts makes no allow<:n1cc for the additional vcet-r befoTc Sale1:i T1\'0 1*:ill need to
~ff-load its first 1/:5 of a core. Intervenors pl:m to fully explore all these factual i:::.s;_~2s at thG hearing scheduled for i.hy 2, 1979.
DiTERVD:OnS' STAl'EHE!\"T OF MATERIAL FACTS IN DISPUTE PERTAI:\ING TO co:rrBITIO:'~ THIRTEEN
- 13. *n1e licensee has failed to give adequate consideration to t,11e cumulati vc impacts of expartd-ing spent fuel storage at Salem Nuclear Generating Station Unit 1 in association with the recently filed proposed ar;-:enment to the application for an operating license at the sister lmit, SaleEl Unit 2.
(See Amendment :.Jo. 42, Docket No. 50-311, filed Anril 12, 1978 h'hich proposes modifications of spent fuel storage which the intervenor believes are similar in scope to the Salem Unit 1 application.). For example, the licensee assumes an .increase in releases of Kr-85 by a factor of 4.5--
due to the factor of 4.5 increase in spent fuel (licensee's application, at 10). A similar increase, absent exce~)tional controls, can be expected at Salem .No. 2, rcsul ting in a cumulative increase .in Kr-85 e:r.rissions by a factor o:i: 9--almost a full ordeT of magnitude increase. (If similm; spent fuel increases ::i.re postulated foT the companion tmi ts, Hope Creek 1 and 2, nrnv uncle r construction, the cumulative increase coulcl rise by a factor of 18, or* almost two full orders of magn.itude.)
In addition to the nl.IE:erous factual issues associated with the need for faul tlcss operation of the SJ.lcm One and Salem Two spent fL1el ~)ools over a long
.period of time (S.ee Hinor affidavit, pages eight through ten), the Colcm::i.;csr Coatention 13 is h110lly misconstn1ed 1Jy P.S.E.&G. in order to avoid the fundar:ental policy thru.s t of 10 C.F. R. Part SO, Appendix I, a11d 10 C. F.R. §zo. L Pursuai"Lt to the latter NRC n~gulation,P.S.E.&G. is required to:
n *** make every reasonable effort to maintain radiation exposures, w.d releases of radioactive materials in efflu.ents to Lmrcstricted areas, as low as is rea.sonablv achievable." 10 C.F.R.
§20 .1. .
Thi.s rule, then, clearly obligates the licensee to r:iake C\'el;' reason.:.~; le effort to i!lJ.intain r::td.iation e.\.11osures as lm~* as is rc<:!sonably achievable in
'.inking all decisior1s on plant. ope-rational modes ai1d not 1,-,crely rcl:t<mcc upon the existing co11tairn11eff~ r:1ec.hai1isns once it has *drastically inc.Teased the rada.i t.ica lo::1d. in the spent fuel pool.* Having made a clecision to" increase t..1-ie public's e)c-posLtrc to radiation, Public Service is uclnci an affirmati vc duty to estaol.i.sh the reasonab 1.eness of this action in light of al tema ti ves that *would not enti3.l such increased e:A.-posure. If not by implementing additional containment measures, the licensee must seek to achieve this standard by *adopting alternatives to the proposed action whicl1 do not result increased radiation e.\.lJOsure~
Therefore, the factual basis for P.S.E.&G. 's conclusion that increasing the public's exposure to Krypton-85 radiation in the entire Salem region constitutes CO!irpliance with 10 C.F.R. Part 50, Appendix I is an issue which can only be re-solved at the plenary hearing scheduled in this matter.
"'P .S.E. &G. hereby seeks. iiiipennssibly to obtain both a shield and Sh'Ord frora the.
ZC'-\.C regulations and rulings peTtaini ng to fa is proceeding. When inter1.renors
<.1ssert that considration be given to tb.e aclqquacr of the srent fuel pool contain-ment in light of the increased risk_; posed by high density storage, they arc told t11at this has been foreclosed by the prior gr<.mt of ar1 open:i.tiun license to the plant, 1vhich fotmJ th.is structure to be adequate. Nonetheless, *when conf-:rnnted .
1,-:j th thr. obligation to maint~in radiation exposure as low as re:i.sonahly achi e\*able, the 1
1 icensee nronoscs to m:.ikc no i\irthcr efforts whatsoever, excent to declare the
- ' L increa.sed exposure to oe iEsign.ific1nt.
Intervcnors respect£ul1y submit tlnt the :\uclear Rep,ulatory Ccmr:1ission' s E:mdate to main ta in radiation as lrn*: c.s reasonablv ad1iev;:ible cons t.i U1tes an din.:-1...:t 'n-e for affirmative action which can not be i~nored in this f~*i.shion.
CO\CLUSICN for a 1l the foregoing rc:usons, tl1e 1icensee 1 s motion for stmm1ary disposition
~:10ulu be ck~nicd.
Respectfully submitted, STA\JLEY C. YA.~ 1'.i'ESS, PUBLIC ADVOCATE BY:
KErI11 A. O.\'SD.J.RFF, ESQC.LRE Attorney for Intcnrenors
-JO-
. ,_,., : ... .i :i ~
- T !-.~* ~ -:-:
'; .... ) ., :'j; J J.*.l..i
_ i 2nt~rtive P2ct on Problems By STEV'S:'I R. W"EI:Si't!AN
~~iai co Tht! ::-.i~*.v *(or:ot "Timt::1
'.'.';~S:-i!NGTON. ::'lfa:rch. 20 - Afi:er ~
r:: .~.r?. *:han a year of l!egot1arior:.s, t:1e 1
.l:-~:r~er?t Energy D~~anm~nt ~a.s.: ~enc.3. .. t r1**~l*r
' .... ~J
- o?"~<l ~o ac,...-c:.oc --~'i::Onsihi 1 i(y - ~
1.4,'::'..I,, .......... .. . .......... .. -..... ... * ~
2.C a rcs3ible cost of seve*r::il b.ul'ldr-ed mil-~
,Uc-n ~!vilars - for ev.~ntuai disposal out-'.~
. s.:de ~--iew -!ork Scace of huge deposits of~
!:i,;hly radioac~iv~ nuciear 'N:lste at U.1.e ~
\-:,*~::~~ ~1:.1lley, ::-i.-'{ _, stonge Zacilicy near i Dt~f~l9. I
.:..t c'.-:e .;ame tim.::, tile Carey adminis- .!
tr~~!iun has agr~~ed. to accept '.ldditionalj a:-:tcums uf auclear ~vaste, prc<l1,1ce<l oy l
- i*.
- dear rnacror.; operati:i.g a*rnund New J
- .:'.:'01'-; State, for interir::i storage at West l VsiU~y until the F:;<le.ral Government j ccr:v::s up *,vit:-t a tong-awaited plan tor l l
l T~~e preilrninary J.gr~~ment beti.vi:;en !
~h~ i~~erg'J SccreL3.r:1, James R~ Sc~1ic:::; ... i
~:1:z:-:c. 2~f.\i the stace $Ovemmec.t, must ~e;
- ,*.9r;r*_)*/:;<l 0y the "i./hite House :tnd Con- l
- g:ess t:e£ore it can *t.J.:'\e e-ffect. 3ut \
- n
- :.rsJ offi~ialst ~.v!:.o ~iisclosed the ac~ord i tadily, saia it consti[med an impor:ant i
~;<:*~kt:ro:g.'1 on ~ne or '-;'1,e so;est_Poi1~s 1
,,., ~r;n._.en,10n b-=tNeen _.,,,bany .:u.d t..e F~~.eral Government.
R-~p~.:-essing 1..:ompany D~runct Ac issue in the somecimes bitter dispute is ~:-ie -:!eiunct Wescem New York C'!uciear, S*;;vice Center, a so--::alled "re;iroce:;sin~ I
~.::~c~lity" on a 3,~~CO-acre site sou(heasL at]
!3'.if'i3\o. lt is th~ *Jniy plant or its :{ind l
,,*,.-?r op~ratetl in ::v:~ l.Inice-J Scates unC:er I
- _)1.
- :-::~y c:ommerc:ai 3.U.Spices. \
'";:1';:: pja.nt. ownE:<l
~t;.;.;:ed :o "Nuc!ear ~~!el Ser:ices, a sub-~
o;i the state '1.nd i s'.:'.'.a::-,r of :he c.:er:y Oil Company, was a*
':~*.-orect ;:>roject or G.Jv. 'Nelson A. Ro<:'.<e-
- o:: !;;r \n ~Sf~J, .:it a tine or high hope:; ~or th-~ f;~~1.t;-e of -::uc!ear pow~r. Le =,v8.s 3;1ur c:;*;.-n :J1 ~:J72, an n.c:. ~owiedg=d symt1)i of
-:>:; f-_I.i.iur.e. or tha r!ation's 2nergy plan-
£>::*:: ~u (!2:..l ...vith ~::e: _;Jroblem of nuc:c~:-
-, : ~,:;~'"~-~~~;:~~an ;; year. t.he Carev ~*d-ci.~::s~rac~o:-1 D::is ~~n ~-z-: ~.g ~a g~t ~!:~ .-..
- _:-:..-*~c-:i ! (,:;ov-=m:-:!~rH :a *:;_ccepr *~:;~er!~~- *
~~:Lt-.r f:>: :..1e nu.c:~a~ *,v1..:.-~2 ~:!a~ :.as Ceen :
'\ :;:,=_ p~a_n:"si~?:. ;,~ ~~:~r.co~:n*.
, .. ,":' c*.ur** o:: L3.1 '" :l pO~lOlc .:.ea1t.1
?D:'n} lI
.,a.~-
~ -t1 "O ':'"l~arbv r 0 sic.l~ncs I Exhibit A 1.- ~;-:~e -'hig...njy --radi~ac.tive matcria.i at.!
'.V::-:;t V:iJley consisrs of' 170 tons or I
- 's;ie!:t" or u*s~-up '1uciear rue! rods ir. I o:torn~e .:;cols; Wl.')~0 C'.lbic reet ot .;olid j
-..-.~~lst:;~ ~:irimarily !eftaver hardware, 3.Ild, J
\';,;::-h3Ds ~;1e rmist :1am.rdous substance .. \
- ,;_1_
- .::1) gallons or ~"1.i.zhly n<lioae:i*Je liq~\
~~~~-~~~ l
~:-::i'.?:f.:lc;_t_gr_:fJ.y_j__:'! bcrjc acid fr_:~l _E_oo1 ch~~~=-?:~~:_ b_Ll_~-~*~!:y_:~~~~-~':."~:-~'.~:*:i
-~,- 1 ,,s~-- a~ *t'-- -:l*t~*,..i=lls --ra -v--=1--0~~ P..1urriinUii1 c::;rr*csion 02~'12.'Jior h~s c .* ::::_ 1__,_1_~::__.::_ ___ 1 __ ;;:::__ ~~-'.<:::. ..::-..'. __ :::_____ ~__::__ c. ___ :=_'.___:'~~ ._. ****------**---------------**-*--*------***-*******--.--
b2::=_;1 s4g__~~~J}_dc;_*r9__ i n__~~:J-~?._~_g_c~-~~9__ .!~.?_~_}_~ 9 q~:---~~-~ 1 i *S_;_J~~:~cl 6C51 a *1 UL1-f ~1.:::-r
- ti.11 *c'Jrrosion d2'12loue,:i en the a1uminu~ c:::..niste;s . fo-~ir;c c..1!J:71~~~-itl bcrrJ.te*
- J ..,J *
. (~1~B~O~)
... ---:--L-::r---
~1n1cn flak2d off. Canside~able ~luminum cJrrasicn alsa acc~~red in r_ (2.'i .;_ 11..2 s Gil d!.::::. : . ',... c~ ~,....;.._"'.:l,.~C'
.:;,.rli-1L.c... _,,
--ov-'...,:::::!
~--* :;Qp.:i G1..1*._ 1..
r- ' 1'C .J-0 .J,*.J.:J-!l C*..,nC.-*
,-.-.J\fr!;l' ,..... .. ~,..,.-'---::i*~...:,....,.,... c . . . "Tlc-
.. 1.., --*~1*_,,i :=l .:.x. -_,*,*',:--~11 _
- -- -*---*---------------------------*--*------**----- ----- -*------*------- -----*--~-
la::ars b~*tl,,;een the cJ.r1ist2':""S and the line-r* minimiz2 cc.*ivcrric cc~7""GSicn o*l:: ;:h.=:
- ---*-------------=----*----***---------*-* -*- ----***-~----
vmcd arid t2ficn 'r'ier2 first usi::<l c:.s insu1a.tc..-s.
both \*ie!'e d2fi ci .::nt. The c_ypress dete;i a;;.?. t*2d in *:;;::.t2.:, a::d -~he t2fl cm d*i d
*-*-----------**--q---*---------*---------------**--- ----*
- ,* 1.~.,-~
m,.--_-*?_-t t~.1::> . .,.., 1"'c~*.ri n-,:- ....
c.,.., *"1**l*r:.i_
... -*1......
, :::..-:::1*,-;--;in,r~ +o li'J*~- Y'ad
. . .. -.J_~~----~- ..::-:_________ ~--------*-=--~--*-~----~~~-:_~-~*-:~~~-;_-*
0.!::1 "r'~r!.1:1<-i 11 1*1 (~ . ./:'""1r'*'-°'7!!'..... ~ ",.~
realaced
- *--.----.-----*---* ~ith silicone* resin.
~------------------
- 1 - -
s rl1*s~~.'~c-~~rl ...... ---- i,~
.. ~~a
~**-
r...,o,1s r'~ ' e"l~'1a*c*.;r.q J ~- ** I ,..,,, 1-hc.
..... *- "1ri*:-.,,,.,..
J _., .__,
+-cm.,-,c*,.;,f-:,*.-::i-
...... ._..,~*- ... , ...... \_.....,I ..... .'.::).
is
.J'23.rs the v~1ue is only ~a.OS% of the full Re3ctar pao1 specific~ticns w**--h----
'-./,l.,;1C\1s~~
C11U
-,~j.:: 1~~1 3.~*-' tL*_ :-rl CU*~
r:i-r-o-
~.,t... r r1*1c*"'J1
\ *,_, .. )
l,,_,
,.;*f*:..~
/r~l ... tl
..:'"._~-:.,,.
,,.__:::l,t~/
,.;.;ca-~*-*.-r.*-~
Ui...>'-~!G.1,;:;*=-1
..c,. ...... 1 1u.:::1
- ...... fi c:.:?u l~~~ 0~ !
ha~~ cvr~a~G~ - 1 \ ._ 11 'l r=~~ri~,,* How2v2r, t~2~2 ar2 na reports th~t ~co1
- V ..J - I ' - ' - i_ ...,J - '--;--- "- - * ...... _, '"
t~~s2r~tur2s
.. have a:prcac~2d 1G0°C.
Lxhibi t B
e e UNITED STATES OF NJERICA NUCLEAR REGULATORY COM1\'IISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD AFFIDAVIT OF GREGORY C. MINOR On Behalf of Intervenors Mr. & Hrs. Alfred Coleman Regarding CONTENTIONS 2, 6, 9 and 13 In the Matter of
. PUBLIC SERVICE ELECTRIC AND GAS CO:C-IPANY, et. al.
Salem Nuclear Generating Station Unit No. 1 Proposed Amendments to Increase Spent Fuel Storage Capacity Docket No. 50-272 March 26, 1979 I. INTRODUCTION Hy name is Gregory C. Minor. I am a partner in Iv111B Technical Associates, a consulting firm located in Palo Alto, California. Hy educational background is in electrical engi-neering (B.S., University of California at Berkeley, 1960, M.S.,
Stanford University, 1966). In addition, I participated in General Electric's 3-year Advanced Course in Engineering,
. . A fu:Ll des c.rip t.ion of my e:z:perie.nce and g"I: ac.:.iJ.:.J. ting in 1963.
~
background is attached at the end *of this affidavit.
During the period between 1960 and 1976, I was employed by General Electric Company in engineering and *management posi-tions involving the design -of components and systems for use on nuc.lear reactors. These systems included reactor monitoring, control, and safety systems. Between 1972 and 1976, I was Hanager of Advanced Control and Instrumentation Engineering; responsible for designs of new safety and control systems whose first application will be on BWR-6 plants.
I am presently a consulting engineer *with MHB Technical Associates, consulting on nuclear power issues for public and private organizations at a state, national, and international level. I am also a member of the Nuclear Power Plant Standards Com..."'llittee for the Instrument Society of A"'TI.erica.
II. STATEMEN~ AND DISCUSSION REGARDIT:TG INTERVENOR'S CONTENTIONS 2 .AND 6 The following is a statement of the Coleman's Contentions 2 and 6. Because they are treated together in the Motion for Sum111ary Disposition, we *will also treat them together:
- 2. The licensee has given inadequate consideration to the occurrence of accidental criticality due to the increased density of compaction of the spent fuel assemblies. Addi-tional consideration of criticality is required due to the following:
A. deterioration of the neut~on absorbtion material provided by the Boral plates located between the spent fuel bundles; B .. deterioration of the rack structure leading to failure of the rack and consequent dislodging of spent fuel bundles:
- 6. The licens~e has given inadequate consideration to qualification and testing of Baral material in the environment of protracted association with spent nuclear fuel, in order to validate its continued properties for reactivity control and integrity.
There are a number of issues of material fact which apply to these contentions and which are not'. adequately addressed in the Applicant's documentation.
A. While there is experience with the materials of the
. * .c
- proposed high density storage racks for Salem, signi.Li-cant uncertainty exists as to the corrosion effect and associated life of the storage racks, including the stainless steel and Baral material.
B. There has b~en degradation of the Baral/stainless steel racks installed at Monticello and Connecticut Yankee reactors. The Applicant claims these problems have"limited relevance to the issues in the procedingn (Liden at paragraph 12). However, there is no evidence presented that assures these same or similar problems will not occur in the proposed racks for Salem.
C. Very little in-service experience is available in storage pool rack.s *with vented cells, as cell venting was not anticipated until leakage and associated swelling recently required modification at the
'Monticello plant.
D. The expedient of venting as a way to deal *with the leakage problem is a major cause of much of the con-cern.over the rack material performance questioned in this contention. The basic design and materials evaluation leading up to this specific design intended .
utilization of leak tight, encapsulated Baral. (Li den at paragraph 6). However, the Applicant has discussed venting at some length. (Applicant's 'Motion at 7, 8, and Liden at paragraph 8). There does not appear to be sufficient analysis by the Applicant of the opera-tion and effectiveness of the racks in the event the cells require venting.
E. The September, 1977 report by Battelle Northwest 1 s A. B. Johnson, Jr. , Behavior of Spent Nuclear Fuel in Water Pool S ~o1~ao-F*
L - o**'11 BNWL-2256, substantiates that the Baral cell venting decision mai have significant corrosion consequences. To quote from page 36 of this report:
"In most cases, pool and fuel bu~dle mater.:ials have appeared to function sat~sfactorily in boric acid fuel pool chemistry, but very few detailed analvses of the materials are available .
.Al Uilll.ffL1'.ll corrosioll 'oeCTa*.7ior nas oeen substall.(!:cc(
1
- I 1 - --,--1 in some borated pools _--~-:...considerable aluD.inuc:r.
corrosion also occurred in crevices on the canisters, perhaps due to oxygen concentration cells." (emphasis added)
This experience seems clearly to indicate the possibility of corrosion problems with the design as currently antici-pated and is certainly an issue of material fact.
F. The NRC in their SER on Salem make the follm-Ting obs er-vation regarding swelling and venting:
"Upon exposure of the Boral plates CB 4 C/Al Matrix) tb. the spent fuel pool i:vater, galvanic coupling between the aluminum-Baral liner, aluminum binder and the stainless steel shroud could occur ..... the hydrogen produced by corrosion of the aluminum *will be released by venting to minimize bulging." (SER at 2-15).
In this instance, it appears the NRC analysis assll!~es the cells are already vented which is contradictory to the Applicant's assumption (Liden at paragraph 9).
G. Based ~n the above, there are sufficient issues of material fact regarding the possible degradation of the rack material to require that these contentions be considered in the.hearing process.
III. STATEJ:*lENT AND DISCUSSION REGARDING INTERVENOR'S CONTENTION 9 The following is a statement of the Coleman Contention 9:
The Licensee has given inadequate consideration to alternatives to the proposed action. In particular, the Licensee has not adequately evaluated alternatives associated with the Nuclear Regulatory Cow.mission adopting the 1
no action' alternative for licensee's application, which would implicate the following:
A. expansion 0£ spent fuel storage capacity at reprocessing plants; B. licensing of independent spent fuel storage installations; C. storage of spent fuel from Salem No. l at the storage pools of other reactors; D. ordering the generation of spent fuel to be stopped or restricted (leading to the slow-do*wn or ter-mination of nuclear power production until ultimate disposition can be effectuated) .
The following are issues of material fact which pertain to the above contention:
A. The Morris Operation has applied for an a!Ilendment of their license which would expan.d their storage facility to 1800 MTHM. However, the NRC in their review of the Applicant's alternatives only considers the existing 750 MTI-lH capacity of H.O. Although they acknowledge that hea-cings for the 1100 HTHM addition are temporarily halted, they could resu..me hearings at at anytime the M.O. mmer (EIA at* 14) decides to do so.
B. The NRC mentions several alternatives which could be available in time to take fuel from the Salem site if a nominal amount of transhipment is employed (EIA at 14, 15, and 16). These possibilities do not appear to have been adequately considered by the Applicant.
C. These facts should be explored in hearings on this contention.
IV. STATEi-IENT AND DISCUSSION REGARDING INTERVENOR 1 S CONTENTION 13 The following ~s a statement of the Coleman Contention 13:
The Licensee has failed to give adequate con-sideration to the cumulative impacts of expanding spent fuel storage at Salem Nuclear Generating Station Unit 1 in association with the recently filed proposed amendment to the* application for an operating license at the sister unit, Salem Unit 2. (See Amendment No. L~2, Docket No. 50-311, filed April 12, 1978 which proposes modifications of spent fuel storage which the intervenor believes are similar in scope to the Salem Unit 1 application.)
For example, the Licensee assu.mes a~ increase in releases of Kr-85 by a factor of 4.5--due to the factor of 4.5 increase in spent fuel (Licensee's application, at 10). A similar increase, abs2nt exceptional controls, can be expected at Salem No. 2, resulting in a cumulative increase in Kr-85 emissions by a factor of 9--almost a full order of magnitude increase. (If similar spent fuel increases are postulated for the companion units, Hope Creek 1 and 2, now under construction, the cumulati,.re increase could rise by a factor or 18, or almost tHo full orders of magnitude.
The following are issues of material £act related to this contention that should be reviewed in a hearing process:
A. The Kr-85 releases discussed in the SER and Applicant's Motion appear to be normal leakage values and do not cover the magnitude of release due to an accident in the pool (such as a cash drop accident) *when there is more than* four times the amount of fuel stored. The NRC includes an arbitrary 114 ci/yr release but does not quantify that in terms of an accident or deterioration of the fuel. (EIA at 7)
B. Applicant's Motion for Summary Disposition states that Zircalloy clad fuel has been stored in U.S. reactors
.spent fuel pools for up to 18 years (Liden at 3). This is only marginally true. As reported in the Johnson report (B:0l1-JL-2256, Sep. 1977, page 14), only one zircalloy fuel bundle of pressurized *water reactor design has been stored in a pool since 1959, and that one is not at a commercial reactor site. Johnson's report also states (on page 3) that "detailed, systematic examinations of fuel bundle materials have not been conducted specifically to define storage behavior, because of the expectation that the fuel would be reprocessed after relatively short pool resi-dence." Johnson recommends that additional investigation
'oe .c pe.rLorme d , " particu
. 1 ar 1 y . .c Lr: h tL.e stored.~ .c ~
.LUeL inventory is expected to move into the twenty to one hundre.d year time fracr1e." The potential impact of longer term storage on radiological releases should be evaluated and discussed by the Applicant.
C. The NRG states that there is~ generic review of load handling operations in the vicinity of spent fuel pools to determine the likelihood of a heavy load impacting fuel in the pool. and, the radiological consequences of such an impact (SER at 2-6). This should be evaluated for Salem as it may represent a much greater release than discussed by the Applicant or the NRC .
.D. The Applicant and the NRC take credit for four yea.rs of discharges of reactor fuel (see for e}zample, EIA at
- 6) but the Applicant admits that maintaining Full Load 11 Discharge cap2.city is prude.nt from an operational s ::and-point. ",*, Such a capacity may also be necessary for safety reasons if major core internals or vessel leakage requires rapid repair to reduce radiological releases to the environment. Therefore, the Applicant's analysis should consider maintaining Full Load Discharge capability and thereby the incremental storage in the new racks is one year old fuel, not four years old.
- '. (Liden at 25)
E. The Morris Operation Consolidated Safety Analysis Report (CSAR) reports an experience of radioactivity release from spent fuel at the Morris Operation in 1975 which caused the radiocesium reading to reach 30 times the maximum permissible concentration in water, MPGw (occupational). (CS.AR 7-8). This appears to contradict the NRC statement that "there has not been any significant leakage of fission products from spent light water reactor fuel stored in the Morris Operation (110) 11 (SER at 6). The possibility of such a leakage and possible release to the environment should be evaluated for Salem.
F. The Applicant has not specified any in-service inspec-tion requirements to verify on-going acceptable performance of spent fuel materials and possible lea:. ~age./
degradation.
G. The Applicant has not indicated any contingency plan for emptying the pool in case of serious degradation or pool leakage.
H. Based on the above issues of material fact. the lnter-venor' s Contention 13 should be addressed in the normal hearing process.
- v. CONCLUSION Based on the issues raised in Sections II, III, and IV of this affidavit, there are material facts regarding Intervenor's (Colemans) Contentions 2, 6 9 and 13 *which need to be resolved in the license amendment hearings for Salem 1 reracking.
LI 7
./~v--r-r_t_.
~ ///1.
{,f7A/l (__,/;/
~ i~/'.rl,1 *'
GREGORY C . MINOR Subscribed and s*worn to before me this - -..-'* - - -dav
... of -'------1979 I
/ -
, '/ ....
J * / *...... ;.
Notary Public commission expires
~---
Gr2 '-'~o:cv C. Hinor 366 California Avenue, Suite 7 Pa.lo Alto, CA 94306 (415)329-0474 1976 - Present
- .MHB Technical Associates, Palo Alto, California. Engi-*
nee ring and Energy consultant to numerous state, federal a.~d private organizations. Hajor activities include studies of safety and risk involved in energy generation, providing technical con-sulting and expert witness to legislative, regulatory, public and private groups. Recently completed co-editing a critique of the Reactor Safety Study (WASH-1400) for the Union of Concerned Scientists and a major risk analysis for the Swedi.sh Energy Comm.is sion.
1972 - 1976
)fanager - Advanced Control and InstrTu-nentation Engineering, General Electric Company, Nuclear Energy Division, San Jose, Californic..
i*la.naged. a design a.i.J.d development group of thirty engi.2ee:cs, t\vo clerical and t<110 technicia...Tls in designing systems for use in the mec.surement, control and operation of nuclea,r reactors. Involved coordination with other reactor design organizations, the Nuclear Regulatory Commission and cus tamers, both overseas and donestic:.
Responsibilities included coordinating 2J.d managing the technical control systems, safety systems and new control concepts for use on the next generation of reactors. Th.e position included res?CL:.-
sibili ty for standards applicable to control and instrlffi:entat:ion, c.s well as the design of short-term solutions to field. proble2s.
The disciplines involved included electrical and mechanical engi-n.eering, seismic design and process computer control/progrcum:1ing.
1970 - 1972
~-r.::inager - Reactor Control Systems Design - General E lee tri c Comp aD_y, Nuclear Energy Division, San Jose, California.
- -~a.naged a group of seven engineers, one technicic*m and cne: cle.::-ical i.;:-i the desi<m0 and pre6aration of the detailed system drawings-e.nd.
control documents relating to safety and emergency systeo.s .tor nuclear reactors.
~ * ..
- Responsiblity required coordination J ,.Ji ch ot:~-i.er
... * .. * .. 1 *
- d.2s ign orgrrnizat:ions and in te rac ti on >:*71. th tne cus toner s eng:;_ne.2:.:-i::g personnel, a.s well as Regulatory personnel.
J.963 ~ 1970 Design Engineer - General Electric Company, Nuclear Energy Division, San Jose., California.
Responsible for the design of speciiic control and instr...22entation systems for nuclear reactors. Lead design responsibility for variol.l.s subsys terns of instrumentation used to measure neutron flux in the reactor during startup and intermediate phase. Performed le2.d system desi6n flli"1.ction in the design of a major system for me<..:i..suring
~,
~ne power generate d in
. nuc_ear 1 reactors. 0 tner responsioi-ities 1 *** 1 . .
included on-site check out and testing of a complete reactor control system at an experimental reactor in the South West. Receive-cl
'Jc.tent for Nuclear Po*wer Monitoring System.
1960 - 1963 Advanced Engineering Progrc.m - General Electric Company, Assignsents in Wc:.shington, California and Arizona.
Rotating assignments in a variety of disciplines:
Reactor maintenance. and instru.-rnent *design, engine2r, KE and D reactors, Hanford, Washington. Circuit des ig~.
and equipment maintenance coordination.
Design Engineer - f.[icrowave Department, Palo Alto, California..
Work on design of cavity coupler3 for TWT 1 s.
Design Engineer - Computer D2p art:men t, Pnoeni:::, P....2:izona.
Design of core driving circuitry.
Design Engineer - Atomic Po*wer Equipmen~ Departraent, San Jose:,
California. Circuit design and analysis.
Design Engineer - Space Systems D2partment, Santa Barbara, Califorrria. Prepare control portion of satellite propo:.:;al.
Technical Staff - Technical Military P l- *a.,..,"."li*no-
.!..:...:.._ o Op 0 -,..- ~-i ~-.,
, . . . . .!..c:!.L.-U.L_.
(TEMPO), Santa Barbara, California. Prepare analysis 0£ missile exchanges.
Di:.ring this period, completed three-yea.r General Electric prograw 0£ extensive education in advanced engineering principles of higher
- nathematics, probability and ai."1.2lysis. Also cow.:pleted coursc::s in T" r-
.:,epn.er- lregoe ~IIecti
- 7 ,.,..,
J
~ *
'le p. . res en ta-cion,
' . iv" ~ ,.,.,
- Li2.nagemen ,_ .Lrainirrg i rogr su
- -::J and various technical seminars.
EDUCATION Cniversity of *California at Berkeley, BSEE, 1960.
_\d,1anced Course in Engineering year Curriculum, Gen2ral Electric Company, 1963 *1 Stanford University, H.SEE, 1966.
HONORS AND ASSOCIATIONS Tau Beta Pi Engineering Honorary Society Co-holder of U.S. Patent No. 3,565,760, "Nuclear Reactor Power Monitoring System", February 1971.
Member: American Association for Advancement of Science.
Member: Nuclear Power Plant Standards Committee, Inst~..J.Bent Society of America.
PEHSON.AL DATA:
Born; JUi.~e 7, 1937
~-farried, three children Heigh i:: 5 ' 8 11
, i\Te2..gh t: 165 lb S.
Health: Excellent J.
l . Tes timor1y by G. C. i*finor, D. G. Bridenbaugh, 2. nd P.... B: Hub*ba::d before the Atomic Safety and Licensing Board, Sep. 25, 19J8, In the f.:'.atter of the Black Fox Nuclear Power Station Construc-tion Permit hearings, Tuisa, Oklahoma.
- 2. Presentation by G.C. Minor before the Federal Ministry for Research and Technology (BMFT), Meeting on Reactor Safety Resea.. --~h
.1...L.: ..... , -.,,..,.,.,;*-:-.,fach.;ne l-c:...I..'" l ... ' ..!...- -
T11t-e~-face
J.. -
- i"n 1\Tucl.=-a~
.i..'~ -- ..t.. no,,,,...t-o-.-c I\.-.._ ...__ J.....J,
- 1 d *,1a11s
- o * - ....
L..
31 arid September 1, 19 7 8 ,. . Bonn* Germany:-
.) . Testimony by G. C. Minor before the California Legislatur*e Assembly Corrrm.ittee on Resources, Land Use and Energy; AB 3108, April 26, 1978, Sacramento, California.
/,
-,. . Testimony by G. C. "Minor before Wisconsin Public Service Commission, February 13, 197 8, subject: Loss of Coolaut Accidents: Their Probability and Couseouenc2.
- s. Swedish Reactor Safety Study: B.e.rsebac.k Risk Assesstrrent,
~mB Technical Associates, January 19 7 8. (Published by s*wedish Departillent of Industry as Document Dsl 1978:1)
- 6. The Risks of Nuclear PoHer Reactors: A Review of the N?,_C Reactor Sa+/-et:y Study WASH-l~UU (NUREG-7:J/01Zr-), H. Kendall., et a.l, ed:.ted by G. C. f.Linor and R. B. hub bard tor the Union of Co:tc2rned Scientists, August 1977.
- 7. Testimony of G. C. Minor before the Cluff Lake Boa::-d of Inquiry, Regina, Saskatchewan, Canada, September 21, 1977.
- 3. Testio.ony of G. C. :Minor regarding the Graienrheinfeld Nucle2.r Plant, March 16-17, 1977, Wurzbu:rg, Gernany.
- 9. Testimony of G. G. Minor and R. B. Hubbard before California State Senate Corrnnittee on Public Utilities, Tra_nsit, and Energy March 23, 1976.
lC. Testimony of D. G. Bridenbaugh, R. B. Hubbard, G. C. "Hin.or to the California State Assembly Committee. on Resourc2s, Land Use,
. and Energy, March 8, 1976.
- 11. Testimony of D. G. Bridenbaugh, R. B. Hubbard, G. C. £*finor be£or2 the Joint Committee on Atomic Energy, hearings held Febr:..:2:-y 18, 1976, and Dublished by Union of Concer;:ied Scientists, Carn.b:::idge,
~*Iassachc:.setts.
- 12. G.C. Minor, W.G. Milc.m, r:Aa Integr2ted Control Room System fo:::-
a Nuclear Power Plant", NED0-1065 8, presented at In. te:rTtatiOLl2.l Nuclear Industries Fair and Techni.cal Meetings, October 1972.,
Bas le, S*witzerland.
- 13. The abo*17e a:::-ticle was also published in the German Technical Hagazine, NT, Ha:?:"ch 1973.
- 14. G. C. Hin.or, S.-E. Moore, "Control Rod Signal Hultiplexing,"
IEEE Transactions on Nuclear Science, Vol. NS-19, Februa~y 1972.
- ~.
UNITED STATES OF f\MERICA NUCLEAR REGULATORY CO:\MIS5IO~i In the M::rtter of ,
'1
)
PUBLIC S.CRVICE ELECnuc & GAS ) Docket No. 50-272
(!.rfl< 1 0:v
.J.J- - .1.-...!.'1 J. '
r.+
,,_.. L.. cal~. ' ) (PToposcd Issuance of Ar..endment I, to Facility Operating License (Salem Nuclear Generating Station, ) No. DPR-70)
Unit 1) )
CERTTPICXIC OF S[RVICE I hereby certify that copies of Meno. and Supporting Afficbvit Ht OppositiQn to the Licensee's notion for SUlTIT'nry Disposition, in the above-captioneU.
proceeding have been served on the following by deposit in the United States r:-tail, first class, this 29th chy of March, 1979.
Troy B .. Conn2~. Jx.~ Es~-
S'-!ite. iosn - __ .. - .
17 .:.l'/ Pr2rtr1s}'"lv2.r:ia A'. :~., t~_.:_t 2crJc:~s v~shi~;tan, D.C-Mr. Lester Kornblith, JT.
i'1ember, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Corunission i\'ashington,. DC 20555
. [! ::.- _ J.,:., r*.: ':: 3 c . I..:.~ ::: b , I I I
~*~~::-:~2~- 7 :'-_:~J:~ ~c S2-E2~y 2~:i I.Lct::~~:..:i.~1; E"*~~-~d. Fe-~:.?~
3~3 t.;r_*~*~:~,~~*{~,:ct:~~:~~\ C:r:::il:'..".:: 2.)7 t:.
c-.:: ~) <: l r
~ :*:.~ :: :~) .:*.L*o,-.,..*.:_r S::f£:*;*'
- ~--~
C-:-: .:* L _\.".~ !_'-:;-~**:::, Esq_
D2?u~y Acto~~0y C~n2c2l
~-;5 !.il;':():l ~-*J2d D2?2rt~2~t of L2~ 2nd Dale !::t-id2rtt>2(tgh Tre~ton, ~e~ Jecsey 0~~25 G~2~*:*c1 r~-- ~*!ir10:-
i-~ _.!£ _B . Techr1ic2l l>:.ssoc:i~t.es Richard Fryling, J~., Esq.
366 C2.lifornic. Avenue:,
Assist2~t G2~2ral S0licitor Palo A~~o, Californi~ 953J6 Public S2~vice ~lectric 2nd G2s Co:-:?2ny 8D I 2rk Pl2c2 1
~~2:.... 2::-1~ ~~2t1 Jersi:::~y 07101 Eleanb~ G. Cale2nn Alfred C. Col222n 35 JiKu Dri"l,.re Pennsville, K2w Jecsey 03070 O.E.:ice cf t::~ S-2:.=::-ci.:2.r.y Dockcti~; ~~~ Ser~ice Section U.S . .i*:uc::lea.::- Reg!..!lato:-y Co=iission
\*i2shing tonj D _C. 20555
./ ,,/-*. _r-"' ----.......
(~//,-,,:l~-),7~(~,i
/ /
~y}-:~ *-_-,.; ./ /
I J **-* "J \_.-( .
KET'TI! A. O:~SDOPJ.:F, ESQUIRE(_ l__./
Attorney for Intervenors