ML19261C422
| ML19261C422 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 03/05/1979 |
| From: | Hansell D ILLINOIS, STATE OF |
| To: | |
| References | |
| NUDOCS 7903220405 | |
| Download: ML19261C422 (4) | |
Text
'
UNITED STATES OF AliERICA NUCLEAR REGULATORY CO!O1ISSION 1.
IN THE MATTER OF:
l'.';w - ),
)
' Docket No. 50-367 D
)
SERVICE CO!iPANY, (Sailly
)
h, Generating Station; Nuclear-1)
)
I, a ";
\\ g' f; {e sf:
' k @a f* gf REQUEST FOR HEARING
~
The People of the State of Illinois
(" Illinois"), by i_ts -
attorney, WILLIAM J.
SCOTT, Attorney General of the State of Illinois, request that the Nuclear Regulatory Commission ( "Commis s ion ")
grant a hearing, pursuant ".: 42 U.S.C.
S2239, on the request dated February 7,
1979 of Northern Indiana Public Service Company ("NIPSCO"),
holder of Construction Permit No. CPPR-104 (the " construction permit")
for the proposed Bailly Generating Station Nuclear-1 ("Bailly"), for an amendment to the construc -ion permit extending the lates t con-struction completion. ate to September 1, 1985.
The interests of the State of Illinois which may be affected by the proceeding, are shown and established in documents in the Commission's docket in this matter.
- This Request should be granted by the Commission itself, or by an Atomic Safety and Licensing Board designated for that purpose.
The Commission's Staff which has served in conflicting and partisan roles in connection with the proposed Bailly Generating Station Nuclear-1 and on the subject matter of this Request should not participate in any way as a decision-maker.
79032204o5' G
Under all of the facts and circumstances the Commission cannot properly determine that the requested amendment involves no significant hazards consideration.
NIPSCO has f ailed to show good cause for the requested amendment as required by 42 U.S.C.
52235, and under all of the f acts and circumstances the Commission cannot properly determine that good cause has been shown.
Illinois reserves the right to supplement this Request for Hearing at a #uture date.
It is being submitted new to ensure that it is before the Commission prior to action being taken on NIPSCO's request for an amendment.
Respectfully submitted, WILLIAM J.
SCOTT Attorney General State of Illinois s
SY:
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i
_s DEAN EANSELL Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601
[312] 793-2491 DATED:
March 5, 1979 CF COUNSEL :
SUSAN SEKULER Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312] 793-2491
CERCIFICATE OF SERVICE I,
DEAN HANSELL, hereby certify that I have served copies of the foregoing Request for Hearing upon each of the following persons by deposit in the United States mail, first class postage prepaid, this 5th day of March, 1979:
Joseph Hendrie Richard Kennedy Chairman Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Peter Bradford Victor Gilinsky Commissioner Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 John Ahearne Director of Nuclear Reactor Commissioner Regulation U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Samuel J. Chilk Chief Public Proceedings Secretary of the Commission Branch U.S. Nuclear Regulatory Office of the Secretary of Commission the Commission Washington, D.C.
20555 U.S. Nuclear Regulatory Commissi Washington, D.C.
20555 William H.
Eichhorn, Esq.
Schroer, Eichhorn and Morrow Jack R. Newman, Esq.
5243 Hohman Avenue Newman, Reis & Axelrad Hammond, Indiana 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 Guy H.
Cunningham, III Assistant Chief Hearing James L. Kelley Counsel Acting General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commissi Commission Washington, D.C.
20555 Washington, D.C.
20555' Richard L. Robbins Steven C.
Goldberg Lake Michigan Federation Counsel for the NRC Regulatory 53 West Jackson Boulevard Staff Chicago, Illinois 60604 U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555
Michael Swygert Robert J. Vollen DePaul School of Law 109 North Dearborn Street 25 East Jackson Boulevard Suite 1300 Room 759 Chicago, Illinois 60602 Chicago, Illinois 60604 Edward W.
Osann, Jr.
Robert L. Graham One IBM Plaza One IBM Plaza Suite 4600 44th Floor Chicago, Illinois 60611 Chicago, Illinois 60611 J. Michael Olszanski Local 1010 United Steel Workers of America 3703 Euclid East Chicago, Illinois 46312 DEAN EANSELL Assistant Attorney General EnvirJnmental Control Division 168 West Randolph Street Suite 2315 Chicago, Illinois 60601
[312] 793-2491
Therefore, on the scale of fuel lifetimes of several years, gaseous and volatile fission products fall into two distinct categories:
(1) short-lived (radioactive) isotopes and (2) stable isotopes (non-radioactive except for 8b;and I29).
1 This dichotomy is significant since the reluse mechanism that has a potential for large releases involves a thermally activated migration process that proceeds slowly.
Because of this relatively slow nigration process, the short-lived isotopes decay appreciably before they are released from the pellet.
Consequently, release calculations for short-lived isotopes must include their decay rate, whereas calculations for stable isotopes do not.
Furthermore, most experimental neasurements of released fission gas are preceeded by a cool-down period of approxi-mately a year, during which time all of the radioactive species (except I29 ) disappear.
Ob;r and 1
As a result of this situation, little or no prototypical data exist for short-lived isotopes that would be useful in determining a release correlation. Gas-release correlations that are based on stable-isotope data, while useful for some #uel-performance calculations, are usually not capable of predicting the radioactive releases.
It is, of course, possible to derive an analytical model that is based on mechanistic or phenomenological principles such that it predicts releases as a function of half life, and such a model can be calibrated with stable gas data. This is the approach taken by ANS-5.4.
The Working Group has chosen what is believed to be the simplest such I-2