ML19275B570
| ML19275B570 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 11/20/1979 |
| From: | Oneill J AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7912110374 | |
| Download: ML19275B570 (10) | |
Text
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@#y,3 iiuCLEAH NEGULAmtr wr.ildalui fore the Atomic Safety and Licensing Joard T
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thz wohn 0 I.eill s contentions sonn v neill submits the following contentions:
- 1. The license hearing should be delayed until the issue of long-term disposal of wastes is decided in the scheduled generic hearing.
This has been established in The State of m inne s o ta vs. u siinu, 602 c.2d 412 ( D.u. c ir,. 19 79 ) and makes good sense; an issue of vital importance to the increased storage f acility has not yet been examined, and the board must wait until a decision has been reached.
Presently, it is likely that the increased fuel assemblies will neve. to remain at 616 Nock beyond the expiration of the plant s license.
Af this occurs, the public s right to a full licensing review of long term stcr s,c will have been denied, because there will simply be nothing to do with the increased amount of sp ent f uel assemblies, save store them at big nock.
Dae process will nave been denied citizens because the licensing preceeding does not address the issue of long term stora;e.
7912110
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.- Consumers Power cannot guarantee that the spent fuel pool will not be used to stcre these materials indefinately, that is on a more or less permanent basis.
IA.
No offsite storage facilities are open now, m2d it is unlikely that any will become available' in the foreseeable future.
- 1. Reprocessing plants are unprofitable..
- 2. There is high cit'izen resistence to toxic raste storage, which would si gnificantly hinder new sitt opening.
- 3. There is no prover' method known f or long term, permanent stor age.
B.
Consumers Power abould be donied a license for this short term storage facility expansion until it can demonstrate convincingly that there will definately be safe off site storage by 1990 1.
No evidence of may type shows that off site storage will be available is presented in the licensing request.
2 The Vermont Yankee and Minnesota plant proceedings revealed that the power companies as well as the NRC know of no solutica to the waste disposal prlblem.
3.
In the event that the license is granted and no solution to this storage problem found is found by 1990, Consumers Power will have been grented a# license"to store radioactive
_b.
wastes at the Charlevoix facility indefinately by merit of necessity, not through proper licensing hearings.
4 The power company is unable to assure the public that the increased number of spent fuel rods will ever leave the Charlevoix crce.
5.
If the stresses of expanded storage continue to the time that the plant 's license expires there is inadequate ascurance in the application that the mater.T als used in the racks.
q the integrity of the fuel tank itself, and the j k cladding and fuel assemblies will remain unchanged, safe and functional.
a.
"tainlose eteel decompocos over time.
Example at E16 Rock found in incident that occured Oct. 19, 1970 and r;c:. reported :. erch 7, 197 b.
The chance of relcaco of radioactivity into the environmcnt increasec c c the structures decay and ac grector lengths of time aller probability of cecicant.
- 6. The same questions become more impcrtant beyond the expiration of the plant's license, when considering the safety of en expanded feel pool, for the above reascns, and bccuute of the effects of time.
_4-7 Consumere Power has not demonstrated that it will remain colvent indefine.tely and thur remain able to indofinately maintain the fuel pool and its increased load of was te.
8 The present request includes an important, unstated but understood alteration of the sense of the original license.
The original license was issued with the understanding that the spent fuel assemblies would be removed about one year aftar being removed from the reactor.
This amendment as written reques. s an increase in the nu=ber t
of fuel rods that may be stored.
mut the issue of how long they nay be store is not addrecsed, and one would assume that the one year term of the original license would still be in effect.
however, the pool is to be expanded precisely to allow extended storage, wi'thout subjecting this issue tu the proper This would then occure if the amendmsnt is issued, without proper licensing or proper public hearing.
Only the problemcof increased capacity, not increased length of storage ic addressed in the proposed amendment. The request as written should be denied.
II All releases of radioactivity from the spent fuel pcol will be aggravated by an increas in the amount of spent fuel stored in the pool of Big Rock.
. II.
Felease of fiadioactivity A.
Routine release of radioactivity =ay cause health and environmental hazards.
Releases include exposure of 27 one time rade to workers installing new racks, releases in evaporttion, nad throu6h the walls and floor of the pool, espe cially the south wall.
It must be kept in mind that the expancico allows the routine releases during core of floadin6 to cont *nue, and the safety of these releases is the importent issue.
- 1. h.sny top scientists and doctors assert with scientific studies that there is no safe level of radiation, no threshold below which a person is safe from cercinogenic and outagenic ef fecta of radiation.
Ernest J. Sternglass, Low-Level Radiation Er. helen Caldicott, Nuclear Madness S.
The environme ntal hazards associated tith small to medium leaks of radioactive water from the pool is not discussed.
Such leaks have occured in Big Rock Plant on August 29,
'78, reported Sept. 17,
'78, and sept. 11,
'79, reported Oct.
10, '79 and other times, and water assumed to be safe was released on August 19, '78 as reported Nov. 26, '78 The envionmental impact of a loss of coolant accident in C.
the pool is not discussed.
This is cdd, for on p. 2-3 of the licensing request,a loss of pool water up to 200 gpm the the is considered possible enough to protect against, effect of the release of all of this water is not considered.
Cataclyssic breach of the containment and loss of coolant D.
is no considered, nor is the impact on the enviornaent mentioned.
. 1.
Possible from impact of a B-52 bomber.
2.
Sabotage from a political group or deranged employee.
-Sheldon Novick interviewing David Brower, The Electric 'lar, p 193.
E.
The effects upon a spent fuel pool with increased number of fuel assemblies of a class 9 reactor accident have not been considered, especiall; the real possib ility that such an accident could cause a severe loss of water accident in'the feel pcol.
- 1. Since Three Mile island, a class 9 reactor accident
/
cannot be considered incredible, and must be taken
/
into consideration.
- 2. A class 9 accident could cause a severe loss of water accident in the fuel pool, and hence, a large release of radiation into the containment building.
This is shom. In the institute for Neactor Safety of the Technical Control associaticn e.V.,
'.7orking Repcrt, otudies Comparing the Greatest Possible Failure Sequences in a Processing Installation and in a nuclear Power Plant, ao C90, August 1576, NBC translatict from the German, #161.
3
- 'he possibility of fuel assemblies that are stored closer together reaching critical mass eventually even seems possitle, Dr.
F. elan Caldfcott, Nuclear madness, p 58, and needs to be considered.
- 4. The containment shell is inadequate protection from massive gamma ray radiation, (PNRC aska Conaumera to study Big Rock's design" Charlevoix Courier, p.1, Wed.
nov 7 1979) which would result from a losa
7 of water accident involving an increased storage capacity at Big Rock, and in light of the significant resulting danger (of deep concern to Big Hock *s insurance company > the license request should be denied.
F.
Absolutely no consideration is given to the concentrating of fission products in the food-chain as the result of any release of radiation from the increased number of fuel assemblies stored.
G.
no studies of the safety of increasing the density at which fuel assemblies are stored, the increascd number of assemblies, and the greatly increased length of storage have been stated as evidence, neither scientific studies conducted by the ancrwr independent group; without adequate scientific evidence the expansion is unwise and should be denied.
III.
Contentions i and 11 considered the possibility of an accident in a storage pool with increased storage capaci ty.
This contention addresses the affect of such an accident on my life.
Social and Economic Impact.
A.
Any accident resulting from increased storage of fuel rods would endanger my life and tha life of my wife, Linda.
The possible cause of such c.ccidents" elaborated through out this paper.
B.
Any accident oc significant public fear of accident or imagined danger would endanger our resturant busin ess, which
depends upon the perception by touriete that the arca is a safe place to vacation.
This is true for many businesses in the area.
C. Like all businesses within 50 miles of Big Rock, cars is not covered by our insurance policy for loss due to an accident or damaging accidental radiation relense frou. a spent fuel pool containit.g more fuel ar.semblies then it ras originally designed t.o hold.
(All insurance policies are exempt from damages from a nucle;r c.ccident '.7hy is the question one is tempted to e.sk.)
The racks have not bean contracted out, nor have actual VI manufacturing specificetions been presented, nor have similar designs.been cited, along with their fabricatora.
For this reason, an adequate evalutticn cannot be made of '.the proposed t.odification.
v.
Should an accident occure involving the increased storage capacity fuel pool, the plant cannot adequately compensate the resident:. of the aret. anc myself, by the Price-Anderson Act.
Since the modificaticri shouldn't be licensed because the company cannot adequately reimburse me should i suffer demcce or injury.
VI~ It is not clear in the licensing report if the present pool meets all the present requiremente for spent fuel pool.
Big Rock is an old plant, and "grandf ather" exemptigns may have been granted its storage pool which could have effects upon Vil The 11cansing hearing should include a review of general plant safety. Including all aspects of power generation and plant and employee management at ciS dock.
deview of general plant safety would provide an a.
indicator of how well the plant structures have withstood nearly 20 years of service, and would help an analysis of bow well analaGous machinery, pipes, racks and materials involved in the spent fuel expansion will hold up for another 20 years.
It will also dive an indication of the present condition.of the equipcent..
B. Review would provide a good measure of the quality of plant administrative proceedures and mana6eme nt, which would have a direct affect on the safe or unsafe operation of the storage facility, and the competence with which modifications can be expected to be made.
This would not constitute a relicensing of the plant, but an investi 6ation of the history of the f acility and its monitors, in an attempt to responsibly determine the future safe operation of an increased spent fuel storage pool.
- viii, Granting of the license is the only way the plant can operate past the year 1981 as things stand now, and thus allow an extension of plant activity that would otherwise be halted.
henCB it is a tacit 7
approval of such extended operation, and should include a review of general plant safety.
-The Kemeny Commissionhas recommended" periodic relicensing of existing atomic plants on the
. Big Rock produces vecy little electricity compared to modern nuclear generators, 72 megawatts at most; the closing of Big Rock would not cause great hardship.
Respectfully submitted, l f%
'l '
L John F. O 'ae 111 LI Route 2, Box 44 maple City, Michigan 49664 November 20, 1979 Copies sent tot herbert Grossman Atomic Safety and Licensing Board U.S. huclear Hegulatory Commission dashinston, D.C.
20555 Janice E. Acore Counsel for NRC Staff U.S. huclear Regulatory Commission
'Asshington, D'.C.
20555 Joseph usilo isham, Lincoln and Beale 1050 17th Street, n.,,.
Seventh Floor Wash ington, D.C.
20036 narin P. Sheldon Sheldon, harmon and Weisa 1725 Str e e t, u.w.
Suite 506 Washington, D.C.
20C06