ML19225B446

Reply to Licensee 790330 & NRC 790406 Responses.Area Will Suffer Economic Dislocations If Plant Is Allowed to Continue to Operate.List of Contentions Encl

ML19225B446
Person / Time
Site:	Turkey Point
Issue date:	04/24/1979
From:	Oncavage M ONCAVAGE, M.
To:
Shared Package
ML19225B432	List: ML19225B430 ML19225B441 ML19225B446
References
NUDOCS 7907250184
Download: ML19225B446 (9)

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UIIITED STATES OF ArdRICA fiUCLSAP, REGUL.'.T0RY COMMISSIOli 4/24/79 BEFOR2 TRE ATOMIC SAFET7 A?ID LICEt!3ING BOARD In the matter of: ) Docket IIos. 50-250 50-251 1lorida Power cnd Light Co.) (Proposed Amendments to Facility Operating License (Turkey Point IIuclear ) to permit Steam Generator Generating Units Nos. Repairs) 3 and 4) )

Petitioner Reply to Licensee Response and NRC Staff Response __

Statements in the Licensee's Response of March 30, 1979 and the NRC Staff hesponse of April 6, 1979 suggest that the Petitior.er possesses no special training or expertise which would contribute toward developing a sound record. The Licensee Responae on page 6 states:

";.s for the second factor, there is no indication that petitioner -- as a result of either training or experience -- would be able to siC nificantly assist in the development of a sound record."

Tha NRC Staff Response, on page 4 states:

"Althouch Petitioner does not allege any facts that wo_ld su gest he is qualified by either specialized ecacation or relevant experience to make a ceuningful contribution to one or more of the contentions he seeks to have litigated, ... "

The justification for these statetant; is not to be found in 10 U?R Furt 2. Paragraph 2.714 Intervention, states:

"Any person whose interest cey be affected by a 3 D proceeding and who desires to pcrticipate as a party f shall file a written petition for leave to intervene."

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attempts to prejudice the petition by suggesting the c[ 3f *a W5 1 D3t/ r e ,T$ 6 #

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petitioner lacks expertise oI upecialized training undernines the spirit and letter of 10 CFR Part 2. The important consideration for granting an intervention must be the protection of the Petitioner's interest irrespective of any axpertise the petitioner =ay or ca,7 not have. If the petitioner's interests have cerit, t h>:0 the recuested intervention will contribute towaru developing a cound record.

Innortant considerations in granting the inster petition cust be given to (ii) The availability of other ceans whereby the petitioner's interest will be protected. And (iv) The extent to which the petitioner's intelest will be represented by exi3;ing parties. The Licensee's Response fails to address either of these i=portant considerations. If the petition is denied, there will be no public hearings to protect the petitioner's interests nor will there be any contribution sede by the general public in this decieion making process.

The legal standing of the petitioner is unquestionr ale.

The petitioner resides on his own property approximately 15 tilas north north west of the ^urkey Point Uuclear facility.

Personal healtn hazards will be encountered by the petitioner,,

his wife, and his infant son if the Licensee releases

. hacardocs a cunts airborne radioactivity during normal ()3di eteorologieui conditions. At 'I 7 hkk e

The petitioner will also suffer econocic losses if the real prope:ty owned by the petitioner becoces contacinated

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with radioactivity.

The petitioner also maintains a sizeable investment of personel property in the form of a recreational sailboat.

If Biscayne Bay becomes contaminated with radioactivity, the recreational activities will be eliminated and the petitioner will suffer economic losses since there will no longer be a market for recreational sailboats.

t,onclusion The intervention sought will complement the examination of the issues by the Atomic Safety and Licensing Board. The perspective is that of a noncerned member of the douth Florida community. The,interventica is warranted.

hespectfully submitted, d4fb & ~fW Mark P. Oncavage OL 4i7 fBM' 4

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G,Y 2, 1979

1. Jhether the operating licenses for Turkey Point Units 3 and 4 should be suspended until the Commission either approves or denies the utility's operating linense amendment application, due to the impaired condition of the steam generators (plugged tubes)?

a) Uhether Turkey Point be allowed to continue operation in an impaired condition, in violation of 10 CFR Part 50, consider-ing impaired cooling apacity due to numerous plugged tubes in the possible event of a loss of coolant accident?

b) iihether Turkey Point be allowed to continue operation in an impaired condition, in violation of 10 CFR Part 20, considering onsite workers are subject to radiation e::posures higher than ALARA due to defective steam generators?

c) .ihether Turkny Point be allowed to continue operation in an impaired condition, .a violation of 10 CFR Parts 50, 100, considering offsite radiation releases higher 55an ALARA

'1hich may end:nger the public health due to defective steam generators?

d ) ;ihether operation ' ? TurMey Point Units Nos. 3 and 4 uith defect;ve or modified steam generators (plugged tubes) conforms with the Faderal .later Pollution Control Act (F.i2CA) ?

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dhether pursaant to requirements of the National Environmental Policy Act (NEPA), 10 CFR Parts 50, 51, the Commission must pre-pare an 2nvironmental Impact Statement on the proposed operating license (CL) amendments, uith specific reference to 10 CFR 50,90?

a) Whether the requirements of the FW2CA are met in the form of inclusion in a NEPA cost / benefit analysis?

3 Jhether the creation of a nuclear vaste storeage facility on site at Turkey Point may be allowed under 10 CFR Part 50, N2PA, or FWPCA, and whether NZPA requires a cost / benefit analysis for an additional commitment of land resources for the disposal of the defective radioactive steam generators?

a) Whether the method of storage of the defective steam generators proposed by the applicant complies with NEPA requirements to protect the environment?

b) Whether a cumulative, accurate monitoring of all sources of ionizing radiation on site at Turkey Point complies with 10 CFR Part 50, NEPA, or potes a potential public health hazard?

4, Jhether the discharge of processed primary coolant violates FJpCA during normal operat.4.cn of Turkey Point !uclear Units

• o s . 3 and 4?

5 Jhethe_ the stear generator repair 4 proposed by the utility Comply with 10 CF2 Part 2 0 , :-l 2 P A , er the FWpCA?

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3 6 Whether the handling, processing, storing, or discharging of primary coolant is in conformance with requirements of 10 CFR Parts 20, 50, 51, 100, NZPA or FU2CA?

7. Whether the discharge of untreated laundry vaste water complies with 10 CFR Parts 20, 50, 51, NZPA or FUFCA?

3 Whether the lac!: of a cumulative, accurate monitoring of all scarces of radiation on site at Turkey Point Nuclear Facility complies uith requirement s of 10 CFR Parts 20, 50, 51, 100, NZPA, and thereby poses a potential public health hazard ?

9 Whether pr':ent fire protection systems meet requirements of 10 CFR Parts 20, 50, and NRC guidelines, or endangers public safety?

10 Whether monitoring of radiation exposures to plant personnc1, including alpha, beta, gamma, ingested alpha, or partial body gamma exposure, is in compliance with requirements of 10 CFR Parts 20, 50, 51, 100 and is U2PA cost-beneficial?

11 Whether monitoring of radiation releases offrite is in com?liance uith 10 CFR Parts 20, 50, 51, 100, N22A, or the FUTCA and vill not endanger the public and the environ.~.ent with inaccurate assessments of offdito releases of radicacti/ity?

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12. Whether the use of transient workers with unknown radiation exposure histories is in compliance uith 10 CF2 Parts 20, 51 or A

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13. Whether adequate consideration of repair alternas ees to the replacement of steat generator louer assemblies, includ ing but not limited to the follouing, has been performed by the licensee in conformance uith 52PA cost / benefit analysis requirements:

a) arresting tube support plate corrosion; b) in-place tube restoration (sleeving);

c) replacement of entire steam generators though a construction opening in the containment vall; d) replacement of entire steam generators through a construction opening in the containment dome; e) in-place steam generator tube replacement (retubing);

f) derating; g) decommissioning; h) bioconversion; O

i) conservation; 4f[ {

j) solar energy; i-) natural gas; or

1) coal?

14 .ihother the lack of a detailed analysis en the prebtbility of rccurring tu'ca leaks in the repaired steam generators is in compliance uiti, the cost / benefit analy:is reqJirements of 1C CF2

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15. Whether the interim measure at 10 CF2 Part 50, Appendix I, establishing a radiation e::posure guideline of G1,000 per man-rem for 31 ant vorkers re? resents a sufficiently high value in light of inflation and in view of testimony before the Advisory Committee on Reactor Safeguards re: Surry Uni:s 1 and 2 on October 28, 1973, at T2 149, indicating a value of $10,000 per man-rom may be more a?propriate?

16. Whether the use of $300,000 per day per unit ior replacement pouer costs for reactor outage is an accurate cost projection basis for assessing cost / benefits as required by 10 CFR Part 51 or N2PA?

17. Whether the licensee proposes to delay the addition of a full-flow condensate polishing demineralizing system and unether it should be considered in an Environnental Impact Statement on stear generator repairs pursuant to 10 CF2 Farts 50, 51 or N2PA?

13. Whether the creation of a long term nuclear vaste storage facility at Turkey Point is in ccmpliance 1 n 10 CFR Parts 50, 51,

2PA, FUFCA, or any laus protecting 3iscayne Bay or Biscyane

ational Monument, their surroundings, and their delicat a life forms, lith particular attention being c'raun to the ?roposed ficorless staae contrator disposal building?

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19. ~.7hether the TurA.2'I <oin u Uni-e "oe

- 3 and 4 should be alloued to opera u e a u ,u_,_, s awe-

-- 1e2e1: uiuh u acou u -90 re cent of the steam genr;_a e o u.3,e we -- .clud ~-

cd during the interim ; cried prior to completion of steam generator repairs and whether such ogoraticn is in compliance with 10 CF2 Part 50?

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