ML19256F858
| ML19256F858 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/10/1979 |
| From: | Mahler J DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7912260363 | |
| Download: ML19256F858 (15) | |
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p UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
)
COMMONWEALTH EDISON COMPANY
)
Docket Nos.
50-454 (Byron Nuclear Power Station,
)
50-455 (OL)
Units 1 and 2)
)
)
STATEMENT OF CONTENTIONS The following contentions are raised against the licensing of Byron Station Units by the DeKalb Area Alliance for Responsible Energy (DAARE) 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 Contention 1 Intervenors contend that the record of noncompliance with Nuclear Regulatory Commission regulations by the Applicant in its other nuclear stations demonstrates its inability, unwillingness, or lack of technical qualifications to operate the Bryon station within NRC regulations and to protect the public health and safety as required under 10 C.F.R. 50.57 (a) (2) (3) (4) and (6), and that therefore the Applic' ant should not be granted an operating license unless it demonstrates that improvements in management, operations, and procedures wi11 ensure its wi11ingness, ability and technical qualifications to operate within NRC rules; that these im-provements will be e:1 forced; and that the Applicant is financially capable of supporting these improvements.
jf}gg 63 7012260 s 6 As bases for this contention, Intervenors cite the following facts and other facts relevant to the contention which may become apparent through the procedures authorized by 10 C.F.R. 2.740-2.744. a. Fines totaling $105,500.00 have been levied upon the Applicant during the years 1974 through 1978 due to the Applicant's non-compliance with the regulations of the Commission. In imposing some of these fines, Commission officials cited the Applicant for " continuing management inadequacies" and "a history of rad-waste management problems" and stated that operating errors in the Applicant's Dresden plant caused " serious concern about the com-pany's (Applicant's) regulatory performance in all of their nuclear plants." b. An 'NRC Board Notification, released February 1977, reports survey and case study findings of plants nationwide, and notes conti-nuing management and operating problems with Applicant's stations, especially Zion, which plant was also selected as the poor per-former case for in-depth case analysis. In 1974, all three stations operated by Applicant were rated "C", the lowest rating given, by the NRC. c. Noncompliance with NRC regulations in 1977 and 1978 in the Dresden facility, including findings that both backup generators were in-operative, 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. 1638 230 d. The nature of the noncompliance by the Applicant with the regulations of the Commission ranges from " licensee event reports" to " viola-tions" with " violations" constituting the most serious charge the Commission can cite as to the operator of a nuclear generating plant. e. The Applicant has reported to the Commission " abnormal occurrences" at the nuclear generating plants wholly or predominantly owned by the Applicant at a rate which is propo tionally in excess of r the rate of " abnormal occurrences" reported by owners of other nuclear generating plants as to those plants in the rest of the United States, f. Former guards at the Cordova nuclear generating plant, owned pre-dominantly by the Applicant, have stated that they were told, by empl3yees of the Cordova nuclear generating plant, not to report certain security violations on forms intended to be reviewed by inspectors for the Commission. A federal grand ju'ry, convened in January, 1978, continues to investigate the propriety of initiating criminal charges based upon the aforesaid statements of these former guards. g. Applicant's record of laxity in the packaging and hauling of low level wastes caused it to be banned from South Carolina's low level waste disposal site and in Washington, all importation of j low level waste was banned after an incident of waste leakage in transport by Applicant. Contention 2 Intervenors contend that since residents of the DeKalb-Sycamore and Rockford areas, the zones of interest of DAARE and SAFE, are surrounded by 11 other nuclear generating units in operation or under construction (at 1638 231 Dresden, Quad-Cities, LaSalle, Zion and Braidwood) in addition to the two units at Byron, that the Applicant should reevaluate the dose impacts of projected routine releases of radioactive materials (Chapter 11, FSAR) to determine the cumulative effects to residents from the addition of Byron releases to releases f rom the other 11 units. This reevaluation is especially critical in light of Applicant's record of incidents at its other plants, since the granting of the Byron Construction License. This reevaulation :Pavid be performed to ensure that applicable NRC (10 C.F.R. Part 20 and 10 C.F.R. Part 50, Appensix 1) and EPA (40 C.F.R.190) limits for radionuclide releases and exposures are not exceeded in practice for DeKalb-Sycamore and Rockford area residents due to the addition of the Byron units to other units in operation or under construction. Contention 2a Due to the concentration of nuclear power plants already in Northern Illinois; the Applicant's record of incidents and violations in existing plants which have emerged since the granting of a Construction License for Byron; and the credibility which must now be given to large scale accident scenarios since TMl, Intervenors contend that the addition of Byron Station operations places an undue and unfair burden of risk f rom exposure to radioactive materials from accidental r61 eases on DeKalb-Sycamore and Rockford area residents. With the addition of two more nuclear power units in operation at Byron, the potential for cumulative dose effects from discrete accinent events at plants in Northern Illinois under unfavorable meterologicti conditions poses an unreasonable level of risk to the health and safety of DeKalb-Sycamore and Rockford area residents. 1638 232 Contention 3 Intervenors content that the FSAR does not adequately describe the elements set forth in 10 C.F.R. Part 50, Appendix E, IV, D as required by 10 C.F.R. Part 50, Appendix E, lll so as to demonstrate that the Applicant's emergency plans for the Byron Station provide reasonable assurance that appropriate measures can and will be taken in the event of an emergency to protect public health and safety and prevent damage to property. Inter-venors further contend that the FSAR does not indicate whether Applicant's emergency plan for Byron takes into account either of the following factors: a. that the evacuation of the affected areas would necessitate the evacuation of more than twenty-thousand students attending Northern Illinois University in DeKalb, most 6f whom rely upon public transportation, or those without cars at other colleges in the affected areas. b. that, in the event of an acute gasoline shortage, coinciding with the need for evacuation, contingency plans for evacuation of those otherwise able to transport themselves by means of gasoline-powered vehicles, including public transportation, would need to be transported by och means. Contention 4 Intervenors contend that the Applicant's Final Safety Analysis Report (FSAR) does not comply with'10 C.F.R. Part 50.34 (b) (4) in that the FSAR fails to take into account all " pertinent information developed since the submittal of the preliminary safety analysis report" as required by 10 C.F.R. Part 50.34 (b) (4). Specifically, Intervenors contend that the FSAR 1638 233 does not analyze the risks to the public heal th and safety f rom the poten-tial of accidents resulting from multiple, mutually independent failures as opposed to a " single failure," as defined in 10 C.F.R. Part 50, Appendix A. Applicant's Chapter 15 FSAR examines a set of single failure scenarios. The potential of multiple failure accidents has become more apparent since March and April of 1979 at which time the nuclear generating plant at Three Mile Island near Harrisburg, Pennsylvania, experienced an accident resulting from multiple, mutually independent failures, that is, failures which occurred in proximate time to one another without actually being caused by one another. In 10 C.F.R. Part 50, Appendix A, Introduction, it is noted that even though no specific design criteria for a prob 1run has been defined, Applicant is not relieved from the obligation to consider new important safety matters, in this case, in its analysis of accident risk and prevention under the requirements of 10 C.F.R. 50.34 (a) (4) (i) and (i.i), and 10 C.F.R. 50.34 (b) (4). Examples of multiple failure accidents can be found ~in a report written by Dr. Richard E. Webb entitled "An Analysis of Three' Mile Island Accident," 1979 Quoting from Chapter 12 of that report: (1) Rupture of a defective control rod drive mechanism (CRDM) housing which causes adjacent, similarly defective CRDM housings to rupture in a cascade manner. Such ruptures could cause the affected control rods to be ejected from the core by the reactor pressure, thereby causing a potentially catastrophic power excursion. (2) Failure of the main feedwater system followed by a scram system failure, which results in a high level of heat generation in the core of the reactor but low heat removal from the reactor system. (3) Seizure of a main coolant pump followed by a scram failure. 1638 234 (4) Continuous withdrawal of control rods with a scram failure. (5) Loss of electric power to the co61 ant pump followed by a scram failure. (6) Loss of turbine steam condenser vacuum with scram failure. (7) Smal, co61 ant pipe rupture wiE1 a scram failure. (8) La'ge coolant pipe rupture followed by failure of the emergency coolant system to function. (9) Spontaneous reactor vessel explosion due to failure of defective closure bolts. (10) Errors in regulating the boron chemical concentration in the reac-tor coolant causing excessive over power transients or power excursions. (11) A large pipe rupture followed by failures of additional pipes and components due to the reaction forces that occur as a result of the pipe rupture. (12) Coolant pipe rupture due to a strong pressure surge caused by a core power or under cooling incident; o a simultaneous rupture of a set of defective control rod drive mechanism housings due to a strong coolant pressure surge, water hammer, or a coolant explosion caused by a molten fuel-water interaction in an accident in which the fuel melts. (13) Steam generator vessel rup tu re. (14) Improper operator actions i. response to a particular accident situa-tion which tends to worsen the accident. (15) Accidents caused by faulty gauges and instruments. 1638 235
. Contention 5 Intervenors contend that Applicant's power demand models in the Environmental Report-Operating License (EROL) no Ic.iger demonstrates that there exists, or will exist in the reasonably foreseeable future, a need for the level of generating capacity which the addition of the Byron units would provide. Such a need must be shown in order to establish that the units produce a level of benefit which will balance the costs of the project under 10 C.F.R. Part 51.21 and 51.20 (b) s intervenors further contend that new conditions and trends have emerged, some of which are described below, and that in consequence the Applicant should reassess its demand projections taking these new facts into account, to determine when and if the generating capacity of the Byron units would be needed to obtain their 14% reserve generating target. Intervenors contend that such a reassess-is necessary in order to fulfill the NRC's obligation under NEPA to ment determine if there exists an alternative, environmentally superior means to meet the real need for power. Such alternatives may include no action. The addition of the Byron station units contributes to a generating a. reserve of 38 percent, substantially above the 14 percent level of reserve deemed adequate by Applicant. The excess reserve capa-city projected by Applicant does not take into account decreasing rates of growth in projected demand due to price and other factors set out below, so that raal overcapacity for generating electricity may be, and have been projected by other sources to be, substan-tially above 38 percent. Even though the value of electricity to fulfill basic needs is " priceless," the value of an excess reserve capacity for generating electricity does not constitute a similarly high level of benefit. 1638 236,
.g_ B b. Applicant purports to show in ER0L, Chapter 1, that demand for power responds to several conditions, including price. New price increases initiated by Applicant, including those in response to rapid increases in factor costs of operations and maintenance, such as fuel costs; storage and disposal costs on and off site of low, intermediate and high level waste; and in wages, and including costs from Applicant's construction program, will all ensure continued price increases and, therefore, according to Applicant's models, a drop in the rate of growth in demand. There is considerable discrepancy between the projections of c. average annual rate of growth in peak load Applicant has made in the EROL and those it has recently made in testimony before other state regQlatory bodies, such that the growth rate now-being pro-jected may be only one-third (.329) the size stated in the ER0L. d. Applicant corrected its original demand projections made for construction licensing downward in the ER0L to account for the effects of the 1973-4 round of oil price increases. The effects of current and expected oil price increases should, if Applicant's ER0L models are correct, further reduce demand. The effects of rapid inflation and the tightened loan market on construction and investments in high energy use appliances should also be con-sidered by Applicant in recal.ulating saturation indices used in making projections. Contention 6 The intervenors contend that the FSAR provides insufficient assurance of containment of radioactive materials. Our evidence for this is contained in a letter to the Bulletin of Atomic Scientists by former Westinghouse 1638 237
.jo. nuclear engineer, Eari A. Gulbransen, published on page 5 of the June, 1975 issue of that journal. Quoting Dr. Gulbransen from that letter: "At the operating temperature of nuclear power reactors zirconium cladding alloys react with oxygen in water to form an oxide layer which partially dissolves in the metal, embrittling and weakening the metal tubing. Part of the hydrogen formed in the zirconium-water reaction dissolves in the metal and may precipitate as a hydride phase also enbrittling and weakening the metal tubing." Further evidence of risk of using zirconium alloys occurs a bit later in the same letter: "At temperatures above 1100 Celsius zirconium reacts rapidly with steam with a large evolution of heat and the formation of free hydrogen, with most metals to form intermetallic compounds and with other metallic oxides to form its own oxide. Once zirconium is heated to 1100 Celsius, which could occur in loss of coolant accidents, it is diffi-cult to prevent further reaction, failure of the tubing and of the reactor." Thus the conclusion is reached by Dr. Gulbransen that: "The use of zirconium alloys as a cladding material for the hot uranium oxide fuel pellets is a very hazardous design concept since zirconium is one of our .nost reactive metals chemically." Contention 7 The Intervenor contends that FSAR offers insufficient safeguards against hydrogen explosions, such as are alleged to have occurred 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 TMl 2 s h< j occur at Byron. Contention 8 Intervenors contend that Applicant does not meet the requirements of 1638 238
s 10 C.F.R. Part 51.21 and 51.20 (a), (1 s 2); (b), (c) because no considera-tion is given the environmental impact of primary coolant system chemical decontamination and steam generator chemical cleaning which the Department of Energy has determined will occur twice during the lifetime of a nuclear power plant. Recent data raise the possibility of serious adverse conse-quences of the decontamination process. Chelating agents, intendsd for the removal of highly radioactive corrosion products adherent to the coolant system surfaces, sharply increase the rate of migration of these same radioactive products through the environment and into' the food chain. No analysis or discussion is given possible biological consequences to the accidental spillage during decontamination, waste storage, transporta-tion or disposal (on or off-site). Contention 9 Intervenors contend that there are many unresolved safety problems with clear health and safety implications and which are demonstrably applicable to the Byron Station design, but are not dealt with adequately in the FSAR. These issues include: a. Serious water hammer problems. We understand that a water hammer caused by rapid condensation of steam in feedwater lines of a PWR constitutes 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 1638 239
~ between the Zion and Byron stations raises serious questions about the Applicant's abi'ity to operate the Byron plant safely, with respect to water ham,er phenomenon. Evidence with respect to demonstrated efficacy of new nozzle designs to be used at Byron to mitigate water hammers is not presented at FSAR 10.4.7.3. 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 significant 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 particularly severe in PWRs. Applicant's response to this problem, a computer model of stresses at FSAR 3.9.1.4.6, is insufficient, and a full scale mechanical test is necessary, especially given the complexity of the reactor vessel geometry. c. Steam generator tube integrity. In PWRs steam generator tube integ-rity is subject to diminution by corrosion, cracking, denting and fatigue cracks. This constitues a 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 out of the containment. A possible solution to this problem could involve redesign of the steam generator, but at FSAR, Section 10.3.5.3 the Applicant notes its intent to deal with this as a maintenance problem, which may not be an adequate response given the instances noted in Con-tention 1, above. 1638 240 d. 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, under certain circumstances, auxiliary electric heat-Ing should, according to NRC generic problem analyses, be provided to keep the temperatures of these structural elements high enough to avoid brittle fracture. The probic:1 may become severe under a LOCA condition. Auxiliary heating is not provided for in the Byron design, as indicated at FSAR 5.2.3.3 or 3.9.3.4. The process of chemical decontamination may exacerbate safety e. problems through a degradation of the-integrity of the primary coolant system boundary. Such degradation may occur during the process of decontamination or during subsequent operation of the reactor. Also, chemical solution decontamination may add to the deposition of radioactive corrosive products, according to an NRC official. Decontamination is not discussed in Applicant's FSAR or ER0L. 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 Byron Station Units. $espectfully, t +t L L c. m t. t / (a.- ./ y J lianne Mahler, Ph.D. A spokesperson for DAARE and SAFE for the intervention. 1638 241
Certificate of Service The undersigned, Julianne Mahler, representing the DeKalb Area Alliance for Responsible Energy and the Sinnissippi Alliance for the Environment, certifies that on this date she sent twenty copies of the attached Statement of Contentions to the Secretary of the Nuclear Rsgulatory Commission and one copy to each of the persons at the addresses shown on the attached service list, by U.S. Mail, postage paid. Dated: December 10, 1979 a (,L 4L/ ltv CR \\
- Julianne Mahler TC' enter for Governmental Studies YJorthern Illinois University De Ka l b, Illinois 60115 1638'242 Service List Marshall E. Miller, Esq., Chairman Ms. Betty Johnson Atomic Safety and Licensing Board 1907 Stratford Lane Panel Rockford, IL 6T107 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, Illinois 60690 Director U.S. Nuclear Regulatory Commission Ms. Beth L. Galbreath Washington, D.C. 20555 734 Parkview Rockford, Illinois 61107 Atomic Safety and Licensing Board Panel Michael
- 1. 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. Daiber Union Carbide Corporation College of Marine Studies P. O. Box Y University of Delaware Oak Ridge, Tennessee 37830 Newark, Delaware 19711 Myron Karman, Esq. Alan P. Bielawski Office of the Executive Legal Isham, Lincoln & Beale Director One First National Plaza U.S. Nuclear Regulatory Commission Suite 4200 Washington, D.C. 20555 Chicago, IL 60603 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 16,38 243 Secretary Attn: Chief, Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555}}