ML19225B570

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Limited Appearance Statement Re Spent Fuel Assemblies Stored in Util & Consequent Radioactive Waste Products Produced Through Fissioning Process
ML19225B570
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 06/11/1979
From: Tippel J
AFFILIATION NOT ASSIGNED
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NUDOCS 7907250533
Download: ML19225B570 (8)


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UNITED STATES OF AMERICA NUCLEAR REULATOL.I CCMMISSION BEFORE THE ATCMIC SAFETY & LICENSING BOARD In the matter of DOCZET NO. 5J-295 CCMMON'4EALTR EDISCN 50-304 ZION SPENT FUEL ? COL ZION NUCLEAR STATION

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Cau-2-k5 50 -Jo y s,p-e-The' entire nuclear fuel cycle has its drawbacks fro = the front to the back end of the cycle, but it is the back end of the fuel cycle that most worries me.

Specifically, I am concerned about the highly toxic waste pro-ducts which are produced through the fissioning process.

'4 hat can be done with this waste o Eow can we isolate it from contact with the environment ? dhy do we keep producing more when we don't knew what

.. u to do with the radicactive. waste we already have" p ~; p.

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a Th,e,7,w n,dustry proponents tell us not to worry; the answer

.. nuclear in is just around the corner. '#c can reprocess it, wury it in salt shafts, shoot it off into space, or let the FederalL_ Department of Energy take care of it... Meanwhile, utilities say, we all need this power, so we'll keep doing you the favor of producing it,.

The problems will work themselves out... b- --

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Sc on the basis of these bland assurances....of safety, the nuclear 3

s industry has continued on unchallenged. In tim e, 'th ey s r_y, solutirc will be found for these problems. Time is fast running out. ~

Commonwealth Edison is here today asking that the USNRC allow them to increase the spent fuel assemblies stored in the. Zion.'poc1 frnm the current limit of So8 spent fuel assemblies to 2112.

h_ hat I would like te do is to give you a brief overview Of what I feel are scme of the p.ajor problems associated with the Zion Nuclear Station spent fuel pool, and Comed's recuest to increast the number of spent fuel assembliet in that pool.

Cne of the mest immediate questions that ecmes :: mind is, why does Comed want to increase the number of assemblies in the poci without =cdifying the pool itself or the cocling systems" Shculdn't it stand to reason that the extra heat genera *ed by the added fuel bf)

J. iirr g y would necessitate additional cooling? Edae# pool that was cr:ginally built to hold 340 spent fuel assemblies need reinforcement to hold 2112 spent fuel assemblies ? Why doesn't Comed just build another pool? It would be much safer. Only if one approaches these questions purely from a profit-oriented perspective will one reach the same conclusions as Comed did.

Plutonium and other radioactive waste products produced by the fissioning process are so highly tuxic that.they must be isiolated from the environment for approximately 250,CCO years. Doea Comed have a plan in hand which would provide for the perpetua1S.,..,ncare of these spent fuel assemblies' Can Comed guarantee a ecnstant supply of water to the pool for any number of years hence ? What condition will the, pool itself be in in twenty years" On March 8, 1979, Neco ( Nuclear Engineering Co.) abandoned the

..u - m Sheffield low-level waste site. Neco had leased the land frem the state of Illinois; they had applied to enlarge the site but had been denied.

~ So,on the grounds that the company could not remnin soluble if it had no wessa coming in, Neco left the state of Illinois with three million cubic feet of low-level waste. How do we know that Comed won ' t go that same route

  • Should Comed abandon the spent fuel pool, whose responsiblity would it be' Che state of Illincis' The federal gevern-ment Comed's ratepayers' Thece are relevant questions which should be answered.

deactors need to be decon=1ssioned at the end of their aseful life, and the same should hold true of the s crage pools. Does Comed have a plan to decommissicn the SFA pool, supposing nc disposal of spent fuel had been developed, and the ; col was full of spent fuel' What if the S?A racks themselves proved defective and swelled together, orwereextremlycorodedandweakzg}} 3 tC W)J-f

J. i ' r% ?qe 2 ~ Radioactivity in the S?? is six times that which is in the Zion reactor.This in itself is an undesirable condition, considering that the routine radioactive releases will reflect this increase. With the proposed expansion of the fuel assemblies, the pool radioactivity will be twenty times that of the reactor! This would result in even higher routine emissions of radioactive gases. Low-level fonizing radiation has been shown to have a negative effect on the human body, sometimes manifesting itself in the form of cancer, especially thyroid cancer. Yet the most serious effect of the pool's high level of radio ~ activity lies in the poss!113 consequences of a reactor or pool accident. An actident occuring in the reactor could affect the stabil-ity of the pool and vice-versa. k a e

Accidents can happen. The history of the Zion reactors themsives prove this point.

According to the Public Resource Center in Washington, the Zion plants have had the highest rate and number of abnormal occurences of any nuclear plant in the US. According to the Advisory Committee en Reacter Safeguards, the Energency Core Cocling System may net be able 2:w % to work at full pcwer, and eese emergency diesel generators have a SC% failure rate. Comed was fined a Octal of 3105,5CC between 1971 and May of 1979 As a safe operntor of nuclear plants, Oc=ed ranks among the lowest. 7iclations which incurred these fines were such incidents as radio-active releases of water, ;ccrly guarding gates and fences, radio-active gas releases because of improper withdrawal of the con r:1 rods (in ene situation),both engines controlling emergency power being shut off, and more.

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,.a..s. ~. w. Isue 7 Sequences which could lead to a serious accident are numerous. A severe accicent in the pool or reactor could make the area unattain-able to repairpersonsrithusian accident.-ofCsufficient: severity could create a situation in which the anaffected reactor or pool could be made off limits to personnel because of high radioactivity. This in turn could cause interruptions in the nornal sequence of operations, causing another accident. So the pool and reactor are not unrelated. Some causal factors which could result in a pool radia. tion release aretas follows: an airplane crash into the reactor or pool; e rec. m tornados--one telephone pole thrown against the containment vessel could rupture it; earthquakes; dropping a new assembly on an old one could cause a criticality accident; anything which could cause a loss-of-water accident could be disastrous as the fuel cladding could spontaneously ignite on ex;ccure to air; and much more. The as sum ptio ns o f inf a' ' i k ' ' ity that und e rlie many re c t o r s o f the nuclear industry is really quite amacing. For one thing, the human error facter is never given the credit it should be in causing problems in reac crs. ForexamplefTheNurre: File acciden s are predominantly caused by operater errors, incorrect installation of equipment, or incorrectly maintained equipnent.The human facter can also account for accidents caused through malice, sabotage, person-ality distortions, anger at employers, basic incompetence, laciness, and mere. Mho can guarantee us tha: the operaters of the Zict pool will always be alert and competent' 'A 1973 AIC report states that,"arreview cf [ e-ating his:Ory associated with 30 operating nuclear reacters in the period 1/1/72 to 5/30/73, approximately 350 abnormal occurences '~ f C '; ?, p

N,. ,ue s were reported to the AEC. Many of the occurences were significant and of a gencic nature requiring follow-up investigations at other plants. ?crty percent of the occurrences were traceable to some extent to design and/or fabrication related deficiencies. The remaining irci-dents were caused by operator error, improper maintenence, inadequate erection control, administratire deficiencies, randem failure, and combinations thereof... Accidents are possible. Does Comed have sufficient insurance to cover potential losses in the event:that the spent fuel melts and expledes ? The Union of Concerned Scientists estimate that such and accident could contaminate an area 500. miles downwind; Dr. Richard 'debb estimates plutonium contamination for over 150,000 square miles. Is Comed financially qualified to handle these losses' Current ICE projections cite 1992 as the target year for im-plementation of spent fuel solutions; since this is 23 years hence, in the interim,shouldn't the Zion SF? be housed in thick concrete instead of the sheet 7-aal? This vruldriend further protection frem inmediate radiation releases. ~ . Since quite a large amouat of lethal material is contained SFF within the fuel reds, has Comed verked out evacuation pls s for eey contingencies' Are these plans on paper There are 7.5 million pecple o in the Chicago metropolitan area. ?]3R 3RIGi@J.

== 452 3s8

Tlf?LL P1 U / In conclusion, it can not be stressed too strongly that the issue of whetner to allow more spent fuel assemblies in the existing Zion poo14 could have an effect on everyone in this state,as well as neighbori'ng states. I drove for four hours to come here and express a my concern and the concern of the Prairie Alliance for Safe Inergy groups in Bloomington-Normal, Feoria, Springfield, Champaign-Urbana, Mattoon-Charleston, and Carbondale.about this issue, We realize that ,*d the outcome of this issue can att.least affect the quality of our lives; ,a at most it could take_away our lives or land. In no way can this issue be regarded frca an isolationist perspective. The effects of your decision could have far-reaching implications, reaching further into the future thsn geographic pollution. Keep in mind that to isolate a tcxin frc= the ecosphere for 250,000 years is a tall order; in fact,the record of the pas: fifteen years is alreadyiseriously flawed. Nuclear power, when viewed with an eye for cc= paring benefits and risks, is rather heavy on the risky side. It would make sense, in situations such as this to act in a manner which could be construed ,; e a ~;- v by some as overcautious; it is best to err t the side of safety. Can Ccned really provids ressenable ast.crance that the health and safety of the public will not be endangered

  • Can you, as e,;m_.

..' the ASL3, make an informed decision tha this propcsed spent fuel increase would ng_t adversely affect the health and safety of-the public (as required by Section1C3 of the AZ Act) o You,as representatives of the NF.C, bear the awesc=e responsiblity of finding that =iddle ground where industry is represented and the people a e protected. 4 Ylw W

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f Should the people of Illinois and the surrounding states ce su - jected to unreasonable risks to health, life, and property for the /i G G 7 }g

T t.s:rt es c40( / 6 1 expediency and p ofit of one company? Sincerely submitted. / 0 t 'M IW Reference materials used in this write-ur include: Chicago Tribune, May 6, 1979, p. 10,section 1 Faul..ner/Ehrlich, The. Silent Bomb,1977, pp. 117-I27. The New York Tines, April 8,1979, p. 4f. Nuclear Power Costs: A Congressional Study, Ryan. Prairie Alliance research papers. The Nuccet File, Union of Concerned Scientists. bour years of reading on this subject. 452 330 .}}