ML19220C007
| ML19220C007 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/21/1975 |
| From: | Silver H Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7904280059 | |
| Download: ML19220C007 (20) | |
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UNITED STATES NUCLEAR A E GU LATO R Y COMMISSION W ASHING TON. O.
C 20555
- 1ay fi, 1975 Acolicants:
"etrocolitan Edison Comoany Jersey Central Pcwer and L'cht Pet.nsylvania Electric C:mp!ny i
Facil ity:
Three Mile Island, Unit 2, Dccket "os. 50-320 SUM"ARY OF MEETING OF "AY 19, 1975 PRICR TO PREHEARING CONFERENCE Cn May 19, 1975, reoresentatives of the intervencrs, the aoplicants, and NRC met to discuss the intervenors contentions in order to excedite the Prehearing Conference scheduled for 'iay 22, 1975.
A list of attendees is attached ( Attachment 1).
Note was made of the desire of the Board to discuss Contention 4 on TMI-l (Manual shutdcwn of ECCS) en 'tay 22.
Contentions were discussed in ceder as presented in Attachment 2; sig-nificant points are itemized below.
In most cases, Mr. Trowbridge indicated serious interrogatories wculd be initiated.
1.
Ccebined Thermal Releases from Facilities on the Lower Suscuehanna River ttr. Kepford exclained his concern is with the effect on lccal climate of the waste heat from the ocwer plants in the area.
2.
Biolacical Survey and Study Mr. Kepford was handed a copy of the updated Environmental Re;crt (ER) of 2/28/75, which he acknowledged he mdy have received but had not yet reviewed. The ER covers the subject matter in question, so the contenticn may be moot. A discussicn took olac about the intent of the NRC in publishing a revised Final Envir nmental Statement (FES) only, or a Draf t Environcer.tal St?toment (JES) and an FES, and the resultant schedules but no conclusion was reached.
3.
Ccolinc Tower Failure The essence of this contention is that the cost-benefit analysis should consider loss of the cooling towers due to earthcuake or tornado, or that the entire plant be designed for these events.
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2 It was agreed that the wording of the contention should be modified by adding to the last sentence:
"or tornado, or until an adecuate NEPA cost-benefit analysis is conducted taking into account the impact of possible loss of cooling towers."
4.
Cacacity Factor Assumotions in Cost Benefit Analysis No changes affecting this contenticn were made in the ucdated ED.
5.
Imor *,f Heavv Ai rcraf t It was agreed to add the following between "C-5A" ar.d "creatly"-
"are reasonably expected to fn!quent Harrisburg International Ai rport and ".
6.
Radioactivity Monitorino Mr. Kepford explained this contention is directed at additional
'real-time" monitoring by the applicant anc the State.
Mr. Trowbridge stated ne feels this attacks the ragulation.
7.
QoodProtection Mr. Kepford's concern is " nth unknown possibly additional effect of cicud seeding on the Probably Maximum Flood (MF).
Mr. Trowbridge indicated he will require specifics and thinks the contention should be reconsidered.
8.
Warnina & Evacuation Plans Little certinent discussion.
9.
Gasecus Radioactivity Release of ALAP Discussion ensued regarding the effect of procosed Accendix I to 10 CFR 50 0 the contention.
Mr. Kepford agreed to add at the end of the irst sentence of the contention:
"of Appencix I of 10 CFR 50. "
10.
Pressure 'lessel Failura It was agreed that since this vessel was not unique, the contention would be dropped.
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Chemical Discharces & Water Cuality Mr. Trowbridge noted that IMI has a cermi* conformina with present EPA discharge concentration limits, whicn have been revised since the contention was written.
NRC must, however, consider the environmental impact in its cost-benefit assessment.
It was agreed that the contention would be modified by deleting all but the first sentence, and in the first sentence changing
" chemicals" to "cnlorine" and adding at the end "which has not been adequately considered in the NEPA cost-benefit analysis."
12.
Indirect Costs It was agreed this contention would be deleted.
- 13. Coolina Tower Plumes and Radioactivity Releases No significant results from the discussion.
For scheduling purposes, it was agreed that the end of discovery should be 12-31-75, and resocnses to recuasts should be within 30 days.
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e Harla / Silver Proj ct Manager LWR franch 2-2 Division of Reactor Licensing Enclosures :
Attachmenc 1 b?!i ' r:'d
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Attachment i "eeting on Prenearing Conference Three ' tile Island, Unit 2
- 1ay 19, 1975 List of Attendees C. R. Kepford, Citizens for a Safe Envircnment & York Comittee for a Safe Environment G. F. Trewbridge, Snaw, Pittman, Potts & Trewbridge E. Blake, Shaw, Pittmen, Potts & Trowbridge D. Reppert, General Public Utilities S. Treby, NRC H. Silver, NRC H. McGurren, NRC 85 Pfi3
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UNITCJ ST.TES ATOMIC ENE~G f C Z 11SSICN
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In the matic: ;f Decket No. 50-J20 Me t ::;ol s. t. n Ec.s:n C - any Jersey Cen t:.:t Powe r :n.
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Pennuylvant. Ele:t:1: "c ;any Three Mile 1:1.n c ilu..
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FCa i t.* ~:V r :TICN Citizens (c: a Icfa Environment, of Harristurg, Pa.,
and the York C
.r..ii t t e e (c a iare Envir:nment, of Ys k,
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- n behalf of their merects and incir families, anc en behalf cf ethc: indivicuals *hr Offs: their support, uncer the authority gf the Ato..ic Enc;jj A:t o f 19 54,Section II(5) and 129 (a),
and Part 2.714 o f Tit.a 10 of t : Code of receral Regulat nc, du hereby 5..tition :n. u. 3. A te:n c Energy C nmissien for le..vc to intervene in thit. :c e e d i n e.:
sebject to tnc Ocmmission's rulse of pr; ctice, a n '. st-tc 1.
Pstit;:nere contand that the Aeplicant n:s failed to consider th: envir.nn.ntal qicct nn tne atmesunere and weather of the c = m c i n..' t ermal rajosses of the genera:1cn fccilitics un :Se lo : lu uen:.nna River.
I 2s ::ntended thct these rslaases '-111 acd a algnificant a f.c u n t o f energy t0 the 10 cal area to ce discipdLed by radiati n and convect;:n with possible alterati:ns in tre 1: cal climate.
detitioners the re fe re ::nterd th ; t co coercting license shculd be granted un:AA such cffects
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2.
Petiti:ners cantand that the bio 10gi:al survey per-formed by the Acplic,nt's concultent is tctally inacecuste.
.It i: little mere thcn c li: ting cf :necies which may be in the area.
Such a litting would : rov abselutaly acrthless es a check :n tne b e f.' r e :nd after imocc: cf T.4I.
?sti-0 tieners c:n t:-d t.$as thc :vgh curvey is necessary, including population c:timatcu an a year-r=,und bccis, ts==:itively assess any :n cible imo.ct o f TM! n the environment.
Peti-tieners tnere fors ennten that no :: crating license shculd p.,
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be granted until tech 9 studf is made.
3.
I'ctitiencre c ntend that the design far tne c: cling towers is in u d e cu a t e to withstand the eartsuvak Or tornacc that th_ rest f thu 31:nt is built to withstend.
As a result, if this eartncuake cces cccur end the main plant does witn-stand it, it is,igN1y Or:bacle that the eccling towers will not.
the p :sibilitats then arace that either the plant will be shut catn for 2 cr 3 years while the t==ers are rebuilt or repsired. or the plant will continue to caerate witncut cooling tcaers, veing enc e-tn:cugh cooling.
If thie latter course were taken, at
_t highly likely that State water quality criteria :uld be violated and severe eniitonmental impacts -culd ensuu (; 4 S.5-C).
It is tnere fore contenced tnat no crercting '.ici.nce ahould be granted TMI Unit 2 until the entire niant i: c.: ::atic o f witn s t:nd an; the maxi um anticipat u eartncue<e.
4 Petitionera contend that the cost-benefit figures used by th A:,,lic an t are falacious.
In partrevlar, the assumpti:n that the unit will operste over its lifetime at a capacity facts: of 0.9 as tot:11y unjustifiec in :ne c;-
ersting histery o f U.3. nuclear reactors.
Through 1373, no reactor (U.S.) had a lifetime uverage capacity o f 0.S, and only t,.o of thirty-seven licensed thr0 ugh 1973 exceeded 0.7.
The, average :,necity factor f:: all licenstf reacters in 1973 was C.55.
Figurs S.4-1 suggests that for creraticn below 5200 heurs per yerr :: a capacity f acter of occut. 59, coal o f fers ec:nonic acv'ntages over nuclear energy generation.
Petitioners therefore contenc that ne c erating license should be gr:nted until the Applicant can justify in a fac-tual mannur its cepacity fact:r assum:ticr.s.
5.
Petitiences v_ntend that the cont 4inment structure, and Other buildings drwigned t: withst.nd cert.in aircraft impact events, :: cf inwdcovate strength to witastand the impact of wirplanes which can be resscnocly excccted to fre-quent Harricourg International Airport.
30th the Boeing 747 and the Lockheed C-5~s creatly exceed the kinctic energy set for the design c:nsiderations.
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Petitieners centend.tnat the environment.1 :scio-activity monitoring ::=g:mm of tne Anglic:nt is totally in-adequate to ac uratsly moniter the dose delivered.: the public during normal :ne sc: cent conditions. Petiti:ners centend that only active, or resi-time detectors can tell what the actual dose rste is.
Furtnermore, en s :ay Of o f f-sita, active detects s could greetly aid in possible evacuetien plans.
Petiti:ners theraf
.e c=ntend thct no op:: sting licenss should =e granted until the A pli:nnt con p;cvide a netwc k of active radiation monitors.
J 7.
Petitioners contend tnat the flood p :tection system for TMI, Unit 2 is inaccquate.
This in becaucH the fic d data p;ssented and tne fl:c d s designed for are Ocsed on historiccl data whi:h co nOt include the inten ti:nal e f f::ts
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of man to e f fect weatner modificata:n.
It is centenced.i o t these efferts render the hist:riesl data of :vestiona:le value.
As shown in Figure 2.5-17 of the Env::enmental Report, tne dike system will not even withstand the p :::cle maximum flo=d.
It is there fore contunded init no Operating license snculd be granted until se effect of hunan efforts at weather nodificati:n are under:tood.
8.
P=titioners contend that the warning nd evacus-tien plans of cath th6 A =licent and the Ccemanwealth of Pennsylvania are inadequate and unworkable.
The "Thres Milt Island Annex to tne Pennsylvanie Plan f: tne Im:le-montation Of P:Otective Acti:n Guide" leav s little doubt that sny,hcurs, if not*a few d:yt nay pass bef :s the ne -
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bers of the cublic in the lcw po:wlation zune or otner members o f the publi at risk might receive cven the most elementary warning o f
'n a :ident.
In parti:ular, in Port VIII of the Annex, the Sequence of Even:= c=mmunica-tion tree makes no mention of any :entingencies.
It must be there f::c assumed that all 1: col and stato officials involved are en 24-hour notica and can be Ocntacted imme-distely.
It further assumes th:.t all peccle notified will promotly soct znd know how to res cnd and are trained in whet to do.
It slao assumes that the public which has been assured thr.t Occidents are "5ignly unlikalj, Shighly im-a p c'beblu", and so on, will ree=end and all w themselves
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to be evacuated. Petiti:ners there fore contend that no operating license sneule ec g :ntec f:: T.ul, Unit 2 until emergency enc evacuati:n alsns een be sm:=n to ce wc kamle through live *usts.
9.
Petitz:ners c:ntend that the rele ses o f g n= ecus radioactivity exceeds the *as 1:w as practic:ble" guicelines.
Systens exist and are in use for significantly recucing emissions from Unit 2.
In a clant of similar ccsign (Rancnc Seco), equicmunt is being utiliced to reduce by a fdctor of 10 the releas-of radioac tive iodine f cm snat expected ::
be :eleasec fr.m T:11, Unit 2.
At the San Cnofre, Unit 1 :lant,
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a cryogenic sy; ten is used to recuce the relesses o f radio-active ncelo gases.
These practi:atle, and work: ole cystext,
,a t modest c st, are av..ilible to reduce by ea;;omimately c facts: of 10 the emiasi:ns o f gaseous racio:ctive fissien
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- om T*41, Unit 2.
Petitioners contend that no ocer. ting license snculd be ;;antec for TMI, Unit 2 until such sy stens, or c=mmara:la 'nes, are 2nst.11cd.
10.
Petitioners cent nd,5at the A li: snt has failed to consider in its sec::ent enaJysis the pos ibility o f pressure ve sci failure or rupture.
As a result, the plant contains no engancered Lafegu arcs ca;able of ::cventing loss of c:alant c: naint ining the c=:c in a shut-c
-n stcte.
Petitieners cuntano tn 4t curtain =ressure vessel f ailure occidants could rencer ::th the Emergency Cire Ccoling System and control : ds unuseale.
Petit::ners tnerefore con *end that no crerating license should be grant-ed until p =ven engineerec safsguards cactble o f preventint disasterous consequences to the ublic f:cm presswre vessel failure are installed.
11.
Petitioners centend that the discharge o f enenicals f:cm Three Mile Island, Unit 2 will hcve an =cverse effect on the water quality.
Chlorine dizcnarges are executed to be higher than levels suggested my the E.P.A.
Di.-narges o f 0.3, arts ner million anc higher can have a cetrimental e f fect en the acuatic 01cnts and animals.
Petitioners cen-tend 15at no oce:3 ting license should be gr.ntec until the Applicant can effer seme reasonable assurance that chlorine disenarges will nct e x c = e d 0.1 :: n at the scint of discharge.
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12.
Petitioners centend that the cost-cenefit analysis of the Applicunt is fculty in that it that it fails to take into account the indirect costs of:
1.
Low cost incemnity insurance by the Price-Ancerson Act 2.
The effect o" the liability ceiling o f $ 563,000,000 on both Price-Andersen indemnity fees and private insurance fees 3.
The subsicy of generetsnq very low cost slectri-City by coal combuction anc hydroelectric dams to drive the gasecus diffusion plants to nake enrich-ed uranium for nuclear power plants, which connot generate electricity as eneaply.
Petitioners contend snat 'no ocerating license should be granted until t%:4e sues 2 dies are quantified and included in the cost-benefit analysis.
13.
"etit:eners ccetend that in its dose calcula*.icns the Applic.nt has ignore 1 the effect of the c c cli ntj t==ers.
I n t e r a c t i.1n betwcen the gascous eleases of radioactivity, in particular. :4dicective iodine isotoccJ. and the cooling tower plumes can increase the thyroid dose by the cu=-milk pathway by u: to a factcr of 10.
Such a pessible increase in the dcse =culd exceed that all0wed by *he "as low as practicabic" quidelines.
Petitienera therefere centend th,t no operating licenJe should ce g:srted until tne Ac=licant
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considers the e f fect of the cooling towers On -he gauenus iodine and :cduces the relcases a,s_necessary.
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