ML19282B105

Petition to Intervene in Licensing Proceedings.Believes License Should Not Be Issued

ML19282B105
Person / Time
Site:	Byron
Issue date:	01/13/1979
From:	Shineflug M DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY
To:
Shared Package
ML19282B106	List: ML19282B105 ML19282B107
References
NUDOCS 7903090020
Download: ML19282B105 (4)

Text

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U.S. NUCLEAR REGULATORY COMMISSION s' EERvia .

D -7 oter of The Proposed Issuance

~g Docket Nos.: STN 50 454 &

uperating License to Commonwealth STN 50-455 Edison Coneany for Units 1 and 2 of the Byron Station FETITICN FOR LEAVE TO INTERVF.NE Jan. 13, 1979 The DeKalb Area Alliance for Paspnsible Energy (DAARE) is a group of 50 members who through education, legislation and direct action are working to bring about the development of safe energy sources. We believe nuclear power in general and the Byron plant in particular constitute a unique, unprecedented and definite hazard to our lives and the lives of future generations. Members of our organization live in and near DeKalb which is located 30 miles from the Byron station. Sinnissippi Alliance for the Environment (SAFE) is an organization which engages in public education on environmental issues. SAFE's principal concern of relevance here is with potential health, safety and environmental problems. Members of our organization live in Rockfoni 16.8 miles or less from the Byron nuclear plant.

Because of our close proximity to the site, this petition for leave to intervene should be granted. Our homes and other property, our places of employment and the environne-' on which we deoend for our very existence all lie within the Nuclear Regulatory Commission's recognized zone of influence. Cur health and safety is affected both by the above mentioned licensing proceedings and by operation of the riant. Existing rules and rule r'anges which govern plant operation have a direct bearing on our health and safety. Errors in the said licensing proceedings could lead to adoption of inadequate rules and/or defective materials which could cause an accident at the plant or other environmental degradation. Operation of the plant could result in an accident and will cause environmental degradation that will directly and adversely affect our health and safety. As resi:ients in close proximity to the 3yron nuclear olant we have a right to raise issues which have a bearing on our health and safety.

The srecific aspects of the subject matter of the proceedings to which we wish to intervene include the following:

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1. Neither Commonwealth Edison nor the NRC has presented a meaningful assessment of the risks associated with the opention of the proposed Byron nuclear plant.

The entire methodology as well as the findings and conclusions of the Rasmussen Reoort on which claims of reactor safety have been based have been discredited.

2. Anewcost/benefitanalysisofthisplantisneeded. Commonwealth Edison Company's "need for power" arguments based on exaggerated demand projections shoulti be re-evaluated. The potential for conservation has not been adequately assessed.

Even the Illinois Comnerce Commission has launched an investigation into Edison's ambitious construction prognm and Moody's Investors Service lowered its rating on this utility's publically held bond issues.

3 The effects of the Byron plant have not been adequately assessed in the Byron Environmental Re: ort or elsewhere. Specifically, no assessnent has been made of the following issues:

(a) The lack of a contnct fou fuel or waste disposal. The waste dump at Sheffield, Ill. for " low-level" mate:isi is closed and at least one state is limiting the amount of such waste it will accept.

(b) The inadequacy of spent fuel sto age facilities in light of compaction and high density rack problems.

(c) The unsolved and unknown cost and waste disposal problems associated with plant decommissioning.

(d) The possible use of plutonium or other fuel at Byron.

4 Evacuation plans for the Byron plant site and surrounding area are inadequate.

5 There is no assurance that the Byron reactors or other plant systems are adequately protected against sabotage either by terrorist groups or by plant employees.

6. New infornation on radiation effects indicates that levels of exrosure pre-vicusly thought safe are in fact harmful. The Byron plant cannot te operated without exposing both employees and members of the public to unsafe levels of radiation ~.

7. There are many unresolved problems--many of which are hign priority safety itens--applicable to the Byron plant. Recent decisions from the NRC Atomic Safety and Licensing Appeal 2oards in the proceedings on River Send and North Anna force the NRC staff to address the unresolved safety problems in all future safety evaluation recorts. High priority unresolved issues include but are not limited to:

(a) Poor steam generator tube integrity. The steam generator tubes uses at the Byron plant are defective in design, :aterials and construction.

Leakage from the tubes during both nor al and accident conditions will cause an increase in radioactive emissions directly affecting our health and safety.

(b) Serious water hammer problems.

(c) Anticipated transients without scram.

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(d) Inadequate design regarding potential asymmetric loading on reactor vessel supports resulting from cer+2in pos*ible coolant pipe ruptures.

(e) Materials used in reactor vessel fabrication are not tough enough to withstand postulated accident conditions.

(f) The fracture toughness of the steam generator tubes and reactor coolant pump support :::aterials needs to be reassessed.

8. The present site for the Byron plant is inappropriate as the reactors are located near the Sandwich fault line and the Plumb River fault line. The latter fault line was not even discovered at the time the Byron Environmental Statement was written. Because of the presence of the fault line, the seismic design of the Byron plant is not adequately conservative.

9. There is an absence of acceptable standards and crite-la governing the control and management of heavy loads near spent fuel.

Becaure of the seriousness of the above mentioned issues, we believe an operating license should not be issued to Commonwealth Edison Company for the Byron nuclear plant.

I hereby certify copies of the enclosed petition for leave to intervene and request for hearing dated January 13, 1979 have been served on the following persons:

1. Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Section

2. Executive Lecal Director U.S. Nuclear Regulatory Consission Washington, D.C. 20555 3 John W. Howe, Esq.

Isham, Lincoln and Seale One First National Plaza Chicago, Ill. 60690 This petition for leave to intervene and request for hearing has been prepared without the assistance of an attorney.

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F rilyn J. Shineflug -

DAAEE

?.0. Box 261, DeKalb, Ill. 60115

U.S. NBC.

A proof of service bearing a signature from SAFE will arrive shortly.

Because of blizzard conditions we request that you accept the late signature.

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• i. / ,o Marilyn Shineflug