ML19211A100

Submits Addl Items to Be Considered in Review of 790629 Request for Suspension or Revocation of Cps.Requests Hearing

ML19211A100
Person / Time
Site:	Marble Hill
Issue date:	09/04/1979
From:	Eyed J SASSAFRAS AUDUBON SOCIETY
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19211A091	List: ML19211A100
References
NUDOCS 7912170031
Download: ML19211A100 (3)

Text

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Mr. Harold R. Denton, Direc ot Office of Nuclear Re:ctor Reculation U.S. I'uclear Reculatory Connicsion Wachington, D.C. 20555

Dear I'r. Denton:

With reference to your letter of Auguct 15, 1979, we accepted your assertion that the cucpencion of certain constnetion activitiec at ?"arble Hill by the Office of Incpec-tien and Enforcenent ("RC) under the ORDER C0" FIR"ING SUSF;"SION OF 00"3TR'.'OTION, while grantinc our petition of June 29, 1979, in one respect, did not autonatically entallish our richt to a Hearinc nder the OMer itself.

• herefore, we have sent to Mr. Victor Stello, Jr., Director, Office of Inspection and Enforcenent (IC), a request for a Hearing precenting argumente to cupport the contention that our interect, synonynouc with that of the public health and safety, would be affected were certain provicionc of the Order custained.

No included ir our Requect to Mr. Stello e lict of quectionc cencernin; the Report of the National Board of Boiler and Pressure Veccel Inspectors to the Ancrican So-ciety of Mechinic11 Encineers (ASI'E). This seemed a proper place to include then an.d by co doin; ue concid'or our statenent in the letter to you of July 27, 1979,

". . .we will file a detailad listinc of concern with the MRO." to be fulfilled.

We should alco like to add several itenc to the lict of those we submitted to you on June 29,1979 (Request to Suspend, page 2), stating that they justified a Hearing on Marble Hill.

1) SITI"1 CRT"ERIA linectone water-bearing layers u .derly the 1'_arble Hill site and the entire recicnal area. The otrata are poroue and faulted. Workere on-site, ac well as observers in a helicopter above the cite, have ob-served what would appear to be " ground-water problenc" at Marble Hill.

Mr. Charles Cutshall described in an affidavit an instance in which water was leaking into a concrete structure for a long period of time at a point where the wall joined the floor. As far as we know this was not reported by an NRO inspector, althouch an incpector wac present when the water was running throuch the structure.

Southern Indiana has had heavy sunner rains (1979) and the helicopter was ascisned to accecs the extent of the flood waterc when certain ob-cervations were made.

The Advisory Connittee on Reactor SafeguzMs (NRO) was concerned with D** T

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the issue of ground water as related to the siting of nuclear re-actors at their July 12, 1979 meetinE, for the hree Mile Island accident had made the idea of a meltdown going through the floor of the containment building a definite possibility. h e Advisory Comnittee discussed steam explosions resulting fro t the core melt-ing through the floor of a containment building and hittir- the water table caucinr a burst of steam to throw radioactive materials into the atmosphere and acerbate the consequences of a Class 9 accident.

Advisory Committee members said that it would be advisallu to re-search the safety consequences of having moving gm und water under a nuclear plant. The potential consequences of such an accident on the Ohio River takes little imagination to visualize.

The burden of pmof of demonstrating whether ground water problems do or do not exist-at Marble Hill should not be on the public. A hearing on safety problems would, however, give the public the op-portunity to raice this concern, learn what the facts of the situ-ation are, and deter-Ane whether a study is needed.

2) SITE EVAC"ATION Can Madicon, Indiana be evacuated in case of a Clacc 9 accident or any accident involving a sidnificant release of radiation?

Thic question hac grown in stature cince Three Mile Islan:1 and the initial Hearing on Farble Hill Anyone faniliar with the roads which lead in and out of Madicon, Indiana, know their potential for slowing traffic many hourc of the day and under the best of circumstances.

The Houce Government (ferations Committee Report on E-ercency plan-nin~ for M:clev !.cciderte (Aupct 1979) reconnende that a FULL SCALE STUDY SE MADE OF THE FEASIBILITY OF EVACUATION AT EACH US NUCLEAR PLANT. We ack that such a study be nade for Marble Hill ac coon as possible and that the incue of site evacuation be con-cidered at a full-scale safety hearing on Marble Hill prior to con-cideration of whether safety-related construction chould recune at Marble Hill.

3) IS PAR" E HIII NEED*Q? AND WJ.T WILL BE THE CO'.;T?

ICI'c rationale for Marble Hill has alway: been based on highly in-flated growth rates of future electric consumptien. By 1979, FSI h1d lowered their esti:mte to a V crowth rate, ctill far above lecc-biased crowth-rate ectinatec. Many group are working to establich anergy conservation progranc in Indiana which will negate the need for rarble Hill completely as far as Indiana citizens are concerned.

While the 6rowth rate of electrical concutption ic declining, the cost of conctmetion of a nuclear plant ic rising sharply. The Nuclear Regulatory Conniscion approved Parble Hill's Units 1 and 2 at a pro-jected coct of $1.4 billion while the total coct at completion in likely to be approximately $4 billion based on the I.U. Supp, et al, study of Trende in Licht Water Resetor Canital Conte in the United Statest Caurec and Correcunreer, Center for Policy Alternatives, Massachusettc Inctitute of Technology, Cambridge, MA, December 18, 1974 1595 214

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If Marble Hill is not needed, and premises to be an excessive economic burden to the ratepayers, should construction be allowed to continuo?

he Sassafrac Audubon Society stron61 Y Protests the decision of the Nuclear Re6u-latory Commicsion to restrict a possible Hearing on the Marble Hill Project to the failure of PSI to institute a quality assurance pro 6 ram for the construction of Marble Hill. . he poor-quality construction of critical buildings has caused a po-tentially dangerouc situation, but the chortcutting of quality construction is symp-tomatic of deeper ills which warrant a full-scale Hearing of *public concerns. We requent the Atonic Safety and Licensing Appeal Boarti to hold a Hearing on whether the construction licence of Marble Hill should be revoked.

urs cince ly John A. Eyed, s' ident Saccafra: Audu n Society 10 0' clock Ridge Road Nashville, Indiata 47 48 ces: Marble Hill service lict 1595 215

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UNITED STATES OF AMEICA NUCLEAR RH3DIATORI CaC4ISSION TO: Harold R. Denton, Director Office of Nuclear Reactor Regulation RE: Public Service Indiana, Inc.

(Marble Hill Nuclear Generating Station, Docket Nos. ST5 50-546 Unita 1 & 2 50-547 A REtUESP TO SUSPEND A"D RE'TCKE CONSTRUCTION PE! NIT AND TO REOPEN SAFEIT hec. RINGS ON MAR 3LE HIII NUCI.ZAR GENERATING STATION The Sassafras Audubon Society petitions the Director of Nuclear Reactor Regulation pursuant to 10 CFR 2.206 of the Nuclear Regulatory Commission's Regulations to suspend and revoke the construction license for Marble Hill Nuclear Generating Station, Units 1 & 2, ard reopen safety hearings on said facility.

Major ennrensental, health, and safety concerns relative to the construction and operation of Marble Hill have developed since issuance of the construction license.

These concerns have either not been addressed, or addressed superficially, at pre-vious hearings, by the Final Environ =entcl Impact Statement, the Pre" Wry Safa-ty Arslysis Report, the Environ = ental Report-Operating License Stage, ard the Final Safety Arn1 7sis Report.

According to the decision of the U.S. Cour; of appeals, District cf Colu=bia, regarding section l?6(a) of the Ato=ic Energy Act and section 50.100 of 13 CFR in ?t. Pierce Utilities v. United States of A= erica and the Nuclear Reg.:latory Co= issien, newly revealed enn:cc= ental, health, and safety problems constitute valid grourds for a post-construction licensing review "under evolving licensing standards, rather than under the stardards applicable when the license was issued"'

and for asking the Nuclear Regulatory Com ission to suspend and revoke a construc-tic = pe = t.

1595 216 We seek to be heard at a meaningful is in an early stage of constmetion, as to whether continued construction ' DUPLICATE DOCUMENT suspension of the construction licens .

ing consideration of public concerns, Entire document previously "arcurd the clock", 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s-a-day, 7 entered into system under:

vould constitute justice denied.

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