ML19282A698
| ML19282A698 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, McGuire  |
| Issue date: | 01/28/1979 |
| From: | Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP |
| To: | |
| References | |
| NUDOCS 7903050487 | |
| Download: ML19282A698 (5) | |
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N09 i-UNITED STATES OF AMERICA
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ITJOLEA". REGULATCEY CQOIISSIQi A
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3 BEFORE THE CQCIISSIQi
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NRC PUBLIC DOCUMERI ROOM In the Matter of
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D'JE PGIER CQ7ANY
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Docket Nos. 50-369
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50-370 McGuire Nuclear Station Units
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50-h13 1 and 2; Catawba Nuclear
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50-h2h Station Units 1 and 2
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CEm' S PETITION TO RECPEI THE SAF?rY PHASES OF LICHISING '
PROCEEDINGS FGt DITE PCd2.8 S MCGIJEE A.id CATAWBA NIJCLEAP. STAfIGTS On Friday, January 20, 1979, this Nuclear Regulatory Com:-dssion said it "does not regard as reliable the Reactor Safety Study's numerical estinate of the overall risk of a reactor accident.n Under this special circumstance CESG, intervenor in the referenced docket numbers, petitions this Connission to reopen the safety phases in the licensing proceedings.
There is good cause to reopen these.atters:
1.
So erroneous was Duke Power Conpany's 1971 estinate of future peak electrical denand that it is a virtual certainty that McGuire unit 2 and Catawba units 1 and 2 will not be recuired at any time in the foreseeable future. The date of initial commercial operation of McGuire unit 1 has been set back seven tines. Duke presently enjoys a 30% reserve. The E:cecutive Director of the Public Staff of the North Ca-olina Public Utilities Comission, Mr. Hugh Wells, stated before the Atomic Safety and Licensing 3 card hearing the safety natters in the operating license proceeding, August 22,1978, that "3ased solely upon satisfying the reserve criteria found necessary and appropriate by the Public Stcff the capacity associated with the fi st McGuire unit will be needed as early 7903050 6/5'7
. as the sunner of 1980 to nect required or reco=nended reliability guidelines" (tr.1823).
Since that time the Public Staff has revised doum:ard its estbate of peak requirenents (Future noctricity Needs For North Carolina:
Load Forecast and Capacity Plan-1978, p.1, item 3).
2.
In the NEPA nandated cost / benefit weighing at the construction permit stage for both McGuire and Catawba the sole benefit cited was the providing of utilizable generating capacity. Abtent the need for such capacity, the cost / benefit weighing becones defective. There renains only cost. The dollar burden on the public is of the order of S2 billion.
3.
The foregoing considerations support a pronpt review by the Co=nission of the risk related to the subject units.
It would appear that if the units are not required for generation that acceptance of the level of risk projected during previous proceedings would not be justified and that an upward revision of risk would nake licensing of these units even less justifiable.
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Specific cattern not adequately dealt with in the record sunport the anticipation that a review of the safety :stters will result in a higher level of rick:
Class 9 accidents were not accorded consideration; Intervenort s assertion, based on test data of the stud bolt stock, that 18% of specinens would nct neet nininun AEG Code requi enents was not rebuttsd; XcGuire and Catawba utilize ice-condenser t,pe prescu o
-3 suppression contaiments. Although internal docunents of the Comission dated 1972 c< press reservations about pressure suppression type contaimcats, Staff did not q
J offer these adverse considerations for the record, although Intervenor expressed concerns very sinilar to those held by some ne:-Joers of the Staff. This conceahent of internal considerations casts a stain on Staff's representations in regard to risk.
- 5. The Rasmussen report was not relied on in making the safety evaluations of either McGuire or Catawba. However those safety evaluations were infected by the sane tendencies that the Comission has found in the Rasmasen report. That repod was largely produced by the sane staff people who contributed to the naking of safety evaluations in licensing proceedings. The deputy director for the Reactor Safety Study was a full time AEC egloyee whose reg de duties had related to the naking of mfety appraisals in licensing proceedings. The Comission should 2
establish whether the same bases were present in the ::cGuire and CatawM licensing proceedings as in the defective Reactor Safety Study:
tha assr:ption that there wre no flaws in the design or in the design premises, namely that the E005 would work, t' rat an ATWS uould not result in serious consequences, etectera; that no operator error would occur; that instr =entation and hardware would continue to prforn over the li'e of the plant as they perforned in shed tem tests. The mr.ber of fault trees considered in the Reactor Safety Study was linited. The Brouns
-h-Ferry plant failure sequence was not considered. Yet a short tine after the issuance of the report resulted in the largest arri nost potentially hanardous nuclear plant failure. Recent actions by the Comission Staff in testing the fire resistance of electrical cables and in correspondence with onerating plants concerning fire hanards nake cicar how deficient the Safety Study was in this regard and, by irplication, how deficied safety evaluations in licensing proceedings.
Will it be necessary to have a cInss 9 accident due to stud bolt deficiencies during an AT.7S; to breach a pressure suppression codaiment in such an event before the Comission concerns itself with these possibilities?
For the good cause sho m, and recognizing the need for prudence in natters of such gravity, the Carolina Enviremedal Study Groun hereby petitions the Comission to reopen hearings on the safety aspects of the McGuire and Catawba plants, especially as they incogorate pressure suppression codainnents, lack the dual, i:riependent control rod syrtens req 2 ired by WASE-1270, and have been challenged as to the adequacy of stud bolt specification cdteria.
Respectfu227 subnitted, y f.
I esse L. Riley Presided, Carolina Enr~ronnedal Study Group At Charlotte, U.C.
January 23, 1979
Joseph M. Hendrie, Chaiman Victor Gilinsky, Richard Kennedy, Peter Bradford, -
John Ahearne, Comissioners, United States Nuclear Regulatory Comission 4