ML19253A866
| ML19253A866 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/30/1979 |
| From: | Von Zellen B DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, NORTHERN ILLINOIS UNIV., DE KALB, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| To: | |
| References | |
| NUDOCS 7909120111 | |
| Download: ML19253A866 (12) | |
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UNITED STATES OF AMERICA
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Aa NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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STATEMENT OF CONTENTIONS The following contentions are raised against the licensing of Byron Station Units by the DeKalb Area Alliance for Responsible Energy ( D,' ".R E )
and the Sinnissippi Alliance for the Environment (SAFE).
These groups were found to have standing to intervene by order of the Chairman of the Atomic Safety and Licensing Board on March 23, 1979 1.
Intervenor contends that the record of noncompliance with Nuclear Regulatory Commission regulations by the Applicant in its other nuclear stations, demonstrates an inability to protect the Public Health and Safe-ty as they must under 10 CFR, 50.57 (a) (1-6) and that therefore the applicant should not be granted an operating license.
a.
Fines totaling $105,500.00 have been levied on the applicant over the year 1974 through 1978 for noncompliance with Nuclear Regulatory Commission Regulations, more than any other nuclear utility in the country. On imposing the fines Nuclear Regulatory Commission officials cited the applicant for " continuing management inadequacies," and "a history of rad waste management problems."
In 1978, the regional NRC Director noted that operating errors in Applicant's Dresden plant caused " serious concern about the company's regulatory performance in til their nuclear plants." This does not, in our view, lead to reasonable assurance that the Byron station will be operated in compli-
$3bM5b ance with NRC regulations.
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. b.
Noncompliance with NRC regulations in 1977 and 1978 in the Dresden facility, including findings that both backup generators were inoper-ative, that there was a valve error in part of a backup system for shutting down the reactor, and errors in testing or maintenance, led NRC to increase their inspection frequency to weekly inspections in the Dresden plant, and in Applicant's other two plants as well in December of 1977 All three of the stations operated by applicant were rated 'c' c.
by the Nuclear Regulatory Commission in 1974.
d.
Noncompliance by the applicar with Nuclear Regulatory Commission regulations range from " licensee event reports" to " violations" -
the most serious charge involving a nuclear power station.
e.
A federal grand jury, convened in January, 1978, continues to in-vestigate criminal charges, stemming from allegations by former guards at the Cordova station, owned predominantly by applicant, that they were told not to report some security violations on forms reviewed by NRC inspectors.
Findings by the grand jury and the courts that the allegations are true would, of course, constitute further evidence that the Applicant cannot provide reasonable assurance that plan oper-ation can be conducted without endangering the health and safety of the public.
2.
Intervenor contends that the licensing of operations at the Bryon station will generate radiation exposures to DeKalb-Sycamore area residents in excess of the levels specified under 10 CFR part 20 and thus will consti-tute a danger to the public health and safety in violation of 10 CFR Part 50.57 (a), (3) and (6).
336264
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. a.
The cumulative exposure to DeKalb-Sycamore area residents f rom the Byron station in addition to 11 other nuclear generating units which surround the area are not taken into account by the Applicant in their analysis of routine releases of radiation in the Final Safety Analysis Report (FSAR), Ch. 11, on the management of gaseous and liquid waste. The cumulative effect of the releases from Bryon Station, added to these made by the other Northern Illinois stations, is to increase the exposure levels for DeKalb-Sycamore residents to several times those projected in FSAR, or those allowed under 10 CFR, Part 20.
b.
Accident analyses in FSAR, Ch. 15, do not take into account cumu-lative accidental radiation exposures to DeKalb-Sycamore area residents which could result from Byron Station accidents in addition to accidents in other Northern Illinois Nuclear generatirg stations.
Such analyses should be performed to provide a full analysis of risk as required under 10 CFR, Part 34, (b), (4) ard (a), (4).
3 Intervenors contend that plans for the evacuation of residents in case of accidents are not specified in the FSAR as required inder 10 CFR, Part 50, Appendix D, IV, D.
Intervenors further contend such plans should contain provisions for:
The evacuation of the more than twenty thousand college students a.
in the DeKalb-Sycamore area, most of whom must rely on public transporta-tion.
b.
Contingency provisions for evacuation in the event of acute gasoline shortages.
4.
Intervenors contend that applicants do not meet the requirements of 10 CFR, Part 50.34, (b), (4) accident analyses for the following reasons:
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. a.
The risk of accident at Byron Station due to multiple, mutually independent failures, that is, failures of the types occurring at the Three Mile Island Reactor 2, has not been appropriately taken into account in the accident risk analysis for Bryon as they must under 10 CFR, Part 50.34 (b), (4). This issue is not to be misinterpreted to imply subsequent failure of corrective measures occurring after a single initiating failure as appropriate to fault tree analysis, but refers to separate, independent failures.
b.
The FSAR, Ch. 15, portrays a series of common to infrequent failures without discussing the risk of their possible interaction, or the effects of such interactions as would be required under a full analysis of risk.
5 Intervenors contend that on the basis of current conditions, the Applicant's power demand models in Environment Report Licensing Stage (ER-L)
Ch. 1, do not show a need for the level of generating capacit) which the addition of the Byron station would provic'e.
Such a need must be shown in order to justify the inevitable direct and indirect environmental and economic costs of the project under 10 CFR, 51.21 and 52.20, (b).
a.
Applicant shows that demand fcr power responds to several conditions including price.
New price increases initiated by Applicant and conti-nuing rapid increases in factor costs of operation, especially fuel costs; storage, and disposal costs of low, intermediate and high level waste', and wages will ensure continued price rises and therefore, accord-ing to Applicant's models, a drop in rate of growth in demand.
b.
Applicants corrected their original demand projections downward for the effect of 1973-74 oil embargo and oil price increases.
Similar current oil price increases, should, if applicant's new (ER-L) models 93G2GG
. are correct, further dampen demand.
c.
The addition of the Bryon plant contributes to a generating capacity of at least 138 percent of demand, substantially above the standard level of overcapacity of 114 percent according to Applicant.
The excess capacity now being projected of 138 percent does not take intu account decreasing rates of growth in current demand so that real overcapacity may be still higher.
w 6.
A revised benefit-cost analysis should be performed as required under 10 CFR 51.21, to reflect new information on *he economic, environmental, and health costs of plant operation, and new conditions affecting benefits from operation.
Such an analysis must show that the bei. #its to the public exceed the direct and indirect costs of the plant to the public in order to justify its operation in the public interest, a.
Costs of decommissioning are not included in the Applicant's benafit-cost analysis.
Information on such costs are now appearing in the liter-ature and estimates should be included, b.
The benefit-cost analysis fails to include the cost of midlife chemical decontaminations, including the cost of outage time of over a year.
The experimental chemical decontamination planned this year for the small 200-megawatt Dresden 1 Reactor is estimated to cost
$36 million (plus $8.7 million from the Department of Energy) and is expected to generate 1200, 55 gallon drums of nuclear waste material.
The Byron Station units are much larger, and costs can be expected to be greater.
c.
Storage costs, direct costs of reactor fuel, direct spent fuel storage costs onsite and offsite are not included.
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. d.
New evidence on indirect health costs of mortality and morbidity associated with the mining of fuels and exposure to low 1evels of radiation is not included.
e.
Associated costs to consumers of supporting capital expenditures to create excess overcapacity (i.e., capacity greater than 114 percent of demand) are not included in the cost benefit analysis.
f.
Indirect environmental and economic costs of accidental exposure (i.e., expected value of the cost of accidents) have not been included.
This area includes valuable croplands which could be put out of use.
g.
Because of the slowed rate of growth in demand, the higher than normal excess capacity for power generation which the Bryon Station adds does not constitute the level of benefit originally anticipated to the residents and rate payers in the area served d;rectly by Common-wealth Edison, h.
Alternative approaches to meeting any real additional need for power, including no action and more powerful incentive based conser',ation pro-grams, are not given thorough consideration in light of current increas-ing direct and indirect nuclear generating costs.
Coal, sind and solar power alternatives are not discussed.
7 The intervenors contend that the FSAR offers insufficient evidence to insure that embrittlement of the zircalloy fuel-element cladding from hydrogen injected into cooling water will not cause early failure of the clad-ding - a, inherent weakness of LW Reactors according to concern expressed by Gulbransen, former Westingaouse nuclear engineer, in the Bulletin of the Atomic Scientists and private communication.
sdmacs 8.
The intervenor contends that FSAR offers insufficient safeguards against hydrogen explosions, such as are alleged to have cccurred at Three Mile Island Reactor 2.
There is no evidence that the recombiners for taking up hydrogen would be adequate if circumstances similar to those at TMI 2 should occur at Byron.
9 Intervenors content that Applicant's Environmental Report does not meet the reQJirements of 10 CFR, Part 51.21 and 51.20 (a), (1 & 2);
(b), (c) for the following reasor,s:
a.
No consideration is given the environmental impact of midlife, chemical decontamination.
New research indicates the possibility of serious adverse consequences of the decontamination process.
Professor Means, et. al., (Science) Vol. 200, 30 June, 1978) raised the issue of substantial environmental consequences
'o the use of chelating agents in the chemical decontamination process.
In addition to the rapid migration through the environment, chelated, radioactive metal ions not removed by demineralization and sequestered in 55 gallon barrels could be flushed to the Rock River where radionuclides in river sediments may become resuspended to enter the human food chain.
No analysis or discussion of this issue appears in the Envrionmental Report-Licensing.
Nuclear Regulatory Commission acknowledges (letter Harold R. Denton c.
to Assistant Attorney General Dean Hansell, dated 21 May) the state of the art chelating agent, Dow Solvent NS-1 itself causes extensive corrosion.
Subsequent radiation consequences to workers have not been determined.
d.
While the benefit-cost analysis asserts negligible thermal plume effects on adult fish, no data are presented on thermal plume effects on fish eggs and larvae.
S3G2G3 10.
The intervenors contend that there are many unresolved safety problems that apply to the Byron plant.
These issues include but are not limited to:
a.
Serious water hammer problems. We understand that a water hammer c6ased by rapid condensation of steam in feedwater lines of a PWR con-stitutes the most serious of this sort of event.
Damage to pipes and valves are some potential hazards. Ultimately, under the most serious circumstances successive water hammer incidents might lead to a loss of coolant accident. Applicant has already had water hammer problems in its Zion plant in 1977, and a plant shutdown was required to repair the damage.
The similarity of plant equipment, management, and operator training programs between the Zion and Byron stations raises serious questions mbout the Applicant's ability to operate the Byron plant
- safely, b.
Asymmetric blowdown loads on reactor primary coolant system.
This problem may develop from a reactor coolant pipe rupture at the vessel nozzle.
The result, after a LOCA incident, could be to place a signi-ficant load on the reactor vessel supports, which, in the extreme, could cause their failure. This, in turn, might damage the ECCS lines and/or prevent proper functioning of the control rods.
This problem is parti-cularly severe in PWRs, but it is not clear what steps have been taken to prevent such a sequence in the Byron system design.
c.
Steam generator tube integrity.
In PWRs steam generator tube integ-rity is subject to diminu; ion by corrosion, cracking, denting and fatigue cracks. This constitutes, hazard both during normal operation and under accident conditions.
Primary loop stress corrosion cracks, will, of course, lead to radioactivity leaks into the secondary loop and thereby 936270
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out of the containment. A possible solution to this proolem could involve redesign of the steam generator.
d.
Reactor pressure vessel materials toughness.
To avoid pressure vessel failure it is essential that the pressure vessel steel maintains its toughness against brittle fracture under long-term neutron bombard-ment and its consequent damage. As the age of any given plant increases, the severity of this problem will increase.
Under conditions of thermal shock as in the case of the operation of ECCS, the pressure vessel may fail and release the coolant.
Neutron damage to pressure vessels may limit the useful life of a vessel to about 20 years.
e.
Fracture toughness of steam generators and reactor coolant pump supports.
The steel used as steam generator and reactor coolant pump support materials may be subject to cracks in the material near a weld under lower-than-normal temperature conditions.
For this reason, un-der certain circumstances, auxiliary electric heating will be provided to keep the temperatures of these structural elements high enough to avoid brittle fracture.
The problem may become severe under a LOCA condition.
f.
Control of heavy loads near spent fuel.
If a heavy object were to fall onto spent fuel in the storage pool and cause damage to the fuel, there could be a release of radioactivity to the environment and possible over-exposure of plar t personnel. Radiation released to the environment could exceed 10 CFR, rart 100 guidelines. With larger spent fuel inventories and longer time of storage, this concern becomes greater.
Stringest requirements should be placed on the movement of heavy loads near stored spent fuel.
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. Conclusion For the reasons described in the above contentions, we urge that the Atomic Safety and Licensing Board not approve the Applicant's request for an Operating License for Bryon Station Units.
Respectfully, l
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l $ / U M L. M I-s Bruce von Zellen, Ph.D.
Department of Biologic Sc' nces Northern Illinois University DeKalb, i11inois 60115 Spokesperson for DAARE and SAFE for the intervention.
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. Certificate of Service The undersigned, Bruce von Zellen, representing the DeKalb Arca Alliance for Responsible Energy and the Sinnissippi Alliance for the Environment, certifies that on this date he sent twenty copies of the attached Statement of Contentions to the Secretary of the Nuclear Regulatory Commission and one copy to each of the persons at the addresses shown on the attached service list, by U.S. Mail, postage paid.
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Dated:
July 30, 1979
'y 'fy-n Bruce von Zellen omina
. Service List Marshalt E. Miller, Esq., Chairman Ms. Betty Johnson Atomic Safety and Licensing Board 1907 Stratford Lane Panel Rockford, IL 61107 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Paul M. Murphy, Esq.
Isham, Lincoln & Beale Dr. Richard F. Cole One First National Plaza Atomic Safety and Licensing Board Suite 4200 Panel Chicago, Illinois 60603 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Cordell Reed Commonwealth Edison Company Richard J. Goddard, Esq.
P. O. Box 767 Office of the Executive Legal Chicago, IL 60690 Director U.S. Nuclear Regulatory Commission Ms. Beth L. Balbreath Washington, D.C.
20555 734 Parkview Rockford, Illinois 61107 Atomic Safety and Licensing Board Panel Michael I. Miller, Esq.
U.S. Nuclear Regulatory Commission Isham, Lincoln & Beale Washington, D.C.
20555 One First National Plaza Suite 4200 Chief Hearing Counsel Chicago, Illinois 60603 Office of the Executive Legal Director C. Allen Bock, Esq.
U.S. Nuclear Regulatory Commission P. O. Box 342 Washington, D.C.
20555 Urbana, Illinois 61801 Dr. A. Dixon Callihan Dr. Franklin C. Dalber Union Carbide Corporation College of Marine Studies P. O. Box Y University of Deleware Oak Ridge, Tennessee 37830 Newark, Delaware 19711 Myron Karman, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Comnission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Secretary Attn: Chief, Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ob5N'S