ML19209C387

Motion,Submitted by Intervenors Coleman,That NRC Amend Request for Order to Show Cause & Stay Licensing.Seek Addl Contentions Re Cost/Benefit Analysis,Seismic Analysis & Class 9 Accidents

ML19209C387
Person / Time
Site:	Salem
Issue date:	08/31/1979
From:	Coleman A, Coleman E AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7910150241
Download: ML19209C387 (6)

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c' In the Matter of a PUBLIC SERVICE ELECTRIC &  : Docket No. 50-311 GAS COMPANY Proposed Issuance i of Operating (Salem Nuclear Generating License CPPR-53 Station, Unit No. 2)  :

PETITION SEEKING ISSUANCE OF AN ORDER TO SHOW CAUSE REQUEST TO STAY LICENSING - MOTION TO AMEND PETITION Alfred C. Coleman, Jr. and Eleanor G. Coleman (husband and wife) hereby petition the Nuclear Regulatory Commission to amend our Petition Seeking Issuance of an Order to Show Cause and Request to Stay Licensing of the Salem Nuclear Generating Station Unit No. 2.

The authority for this request is granted by the Atomic Energy Act of 1954, as amended (the Act) and.the regulation in Title 10 Code of Federal Regulations, Part 2 730 Motions.

Additional research and investigation has uncovered substantive information which should be considered during your deliberation.

ADDENDUM NO. 7A 7A. The Nuclear Regulatory Commission has failed to require the licensee and/or the manufacture of reactor /

steam generators to retrofit, as a result of testing, evaluating and analysis from " lessons learned" from the 1146 292 mois o Z$q

1974 incident in Switzerland (Westinghouse Reactor) and Davis-Besse Unit No. 1, Ohio (Licensee: Toledo Edison Co. - Docket No.

50-346).

ADDITT_0NAL CONTENTIONS

8. The Nuclear Regulatory Commission has failed to require of the licensee cost-benefit analysis and consideration of alternative conversion of Salem No. 2 to natural gas or coal.

(Final Environmental Impact Statement - Docket Nos. 50-272 and 50-311 - April,1973 - Pages 10 Alternatires,10-1 through 10-17 and 12-9 (12Q) and '.2-16 (12X). The NRC has failed to require in their analysis of " Request fo r Additional Financial Information Concerning Unit No. 2" (NRC request to PSE&G, April 18, 1978 -

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Olan D. Parr to R. L. Mittl) the alternative of conversion to natural ga's or coal.

C. The NRC has failed to review and compel licensee to explain apparent discrepancies in seismic findings by Dames 4 Moore for PSE&G and Delmarva Power and Light Co. (Summit Nuclear Plant - Delaware) as it relates to the effect of a possible earthquak e . The final Safety Analysis Report reflects there is no earthquake fault in the vicinity of Artificial Island, site of Salem Nuclear Generating Station No. 1 and 2.

This appears to be in contrast to the study and findings 1146 293

of the Univeruity of Delaware which states there is a fault down the middle of the Delaware River. This study is available to the NRC Staff. The NRC Staff order for seismic inspection of 29 reactors failed to include reactor contaiament structure, fuel handling and spent fuel pool facilities. Tais must be deter ,' y prior to licensing Salem Unit No. 2. (Attachment -

Article from "Today's Sunbeam," August 24, 1979) The NRC is already aware of the condition of the containment building (reactor) (cracks - NRC inspection report) and is unable to determine width, depth, r,xtent or cause because of sand blasting by licensee trior to NRC inspection. _

10. The NRC has failed to require the licensee to consider evaluate, and analyze the possible effects of a Class 9 accident for the Salem Nuclear Generating Station.

Refer Final Environmental Impact Statement (FEIS) dated April, 1973, page 7-1 paragraph starting with, "The applicant's report has been evaluated, using the standard accident assumptions and guidance issued as a proposed amendment to Appendix D of CFR Part 50 by the Commission on December 1, 1971. Nine classes...."

Durther refer to Table 71, page 7-2 O US), Classification of Postulated Accidents and Occurrences, Cla,s 9 0 Hypothetical sequence of failures more severe than Class 8.0 - Not considered.

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As a result of a request (under Freedom of Information to NRC) to the NRC, I received correspondence on August 22, 1979 (FOIA-79-288) referring to PSE&G's correspondence dated November 12, 1973, which was submitted as Amendment No. 25 to the applications under Docket Nos. 50-272 and >S-311.

Referring to Exhibit V, Page 1, Board of Directors, Janmery 16, 1968 (Public Service Electric & Gas Company), the chairman stated that,". . .in discussions with the Adv isory Committee on Reactor Safeguards and the staff of the Atomic Energy Commission '(present NRC) it was indicated they were unwilling to recommend that the Atomic Energy Commission issue a _icense at this time for the construction of nuclear units at '.he proposed site of Burlington Nuclear Generating Station because of its proximity to densely populated areas (with emphasis),

and that accordingly the Company (PSE&G) has investigated alternative sites." Further, "...instead on a tract of land of approximately 700 acres, in Lower Alloways Creek Township, Salem County, New Jersey (Artificial Island)."

There is no question that the Staff of the Advisory Committee on Reactor Safeguards and staff of the Atomic Energy Commission did, in fact, consider an hypothetical sequence of

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failures core severe than a Class 8, an " extraordinary occurrence."

The licensee sendment was considered and accepted by the Staff (AEC-NRC) based on their (NRC) consideration of population density and its effect (Class 9 accident - greater than a Class 8) on the health, safety and welfare of the people living in the vicinity of the then, proposed Burlington Nuclear Generating Stations No. 1 and 2, on the east bank of the Delawat e River on the boundary be-tween Burlington City and Burlington Township, Burlington County, New Jersey.

The change in location, based on population density, to Artificial Island (low population) is an admission on the part of the NRC (previously AEC) of hypothetical accident greater than a Class 8. Even the "so-called" low probability of Class 9 was sufficient to change the siting of the Burlington facilities to Artificial Island, Lower Alloways Creek, Salem County.

Until March 28, 1979 (Three-Mile Island Unit No. 2), an incident or worst-possible-case accident had not been considered possible (Class 9), yet the NRC Staff has concluded, "

...the Staff nonetheless concludes that the accident at Three-Mile Island was a Class 9 accident (NRC Staff Response to Board Question No. 4, dated August 24, 1979, Docket No. 50-272 signed by Counsel for NRC Staff, Barry H. Smith)."

We hereby file a Motion to Amend and add Contentions 8, 9 and 10 because of substantive information received after the original petition was submitted on Augus+ 2,1979.

1146 296 Dates Alfred C. Coleman Eleanor G. Coleman

Seismic safeguards .

delay Salem I start "

m computer codes and examining pipe t ny DAVID AI.TANEft hangers and straps for minute cracks, C 3 Sunbeam Staff 1,0WER AI,1,0 WAYS CHEEK-The according to l ublic Service and Electric I

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, and Gas (PSE&G) ro spokesman e

$ re+pening of the shut-down Salem I reactor will he delayed one more time, Pat rick Wheeler. Calling the analysis an

' involved and lengthy process," y ,.fy 4 3 ~

as cor. par.y e mployees conduct a Wheeler said company technicians and b.

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Nuc! car Iteguktory Commission-order. outside consultants were working ed inspection. ' over-time on the protect.

• The reactor shut down in early April, The pipes, for the most part, supply f and had been scheduled to go back into cooling water to the reactor, and range y 4 D operation in June. But a series of I in sire from one inch to three feet in dia-mechanical problems ranging from meter, Wheeler said.

g', broken control rods to torn fuel Company estimates on how much g assembly straps have several times money the shutdawn is costing con-

• g delayed the opening, this time until at sumers ranges from $300,004$500,000 a .

least mid4)ctober, y r,,,,) day, depending on where the replace- '

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Salem I is among 29 reactors in the ment energy is coming from, and how h country being asked to shut down in order to undergo testing in order to much electricity is in demand. /

g determine their ability to withstand The first problem discovered at the rn reactor since it shut down for refueling

, earthquakes. was in May, when company employees The move is similar to a NRC-ordered discovered straps used to hold the fuel ,,.A h shutdown of five nucIcar reactors in assemblies in place had accidently February. 'The NRC ordered the reac. lecome lorn. It was remedied by replac-tors to close down because of errors in ing the assemblies with torn straps with CD computer codes, or because estimates of some that had been scheduled for

,a earthquake probability were too conser. removal. ,

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>' vative. In early June, several control rods The analysis will involve checking ~ ,,

were found to have been broke'n, Control

[-. rods regulate the speed'of the fission process within the reactor. When the rods are fully inserted, the process 7 stops. When they are fully withdrawn, .{ ]

the reactor operates at full speed. Alj l The broken control rods were replaced uith new ones from the Salem 11 reac- g

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( In late June, cracks were discovered in the lines that feed water to the steam M~ f [

sem see. ., u.,,, o.,,,,

} generators (boilers) in the reactor. All four pipelines wm recently replaced. EARTIIQUAKE TESTING-The re-opening of Salem I will be The most recent prob.t.n was a mass delayed by an NRC-ordered testing for capability to withstand of highly radioactjve material discover- earth uakes. Ab , PSE&G spokesman Patrick Wheeler poims at ed lodged in a pipe leading from the the type of Pi Pes and the,r i straps which will be examined in the test reactor's core to a large tank containing .

water used during refueling. The piece Ing. The picture, however, shows not Salem I, out its identical twm, of material, teheved to be a resin build- Salem II up caused by a faulty filter, was flushed out and removed

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