ML19282B152
| ML19282B152 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/13/1979 |
| From: | Johnson B LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL |
| To: | |
| References | |
| NUDOCS 7903090160 | |
| Download: ML19282B152 (5) | |
Text
N-UNITED STATES OF AMERICA Q \\ P !/,J; NUCLEAR REGULATORY COMMISSION NRQ PUBLIC DOCIEIENT ROOM E
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-h vygNkv ttr, Matter of Commonweal th Edison Company, Byron Station, Uni tsl & 2, n
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50454and50-455$ Application for Facility h
- ,*g Docket Nos.
e"g.W Operating Licenses o
N PETITION FOR LEAVE TO INTERVENE The League of Women Voters of Rockford, Illinois on it's own behalf and on behalf of it's members, hereby petition the Nuclear Regulatory Commission (NRC) for leave to intervene in the above-captioned matter pursuant to Section 2.714 of the NRC's Rules of Practice.
Identification of Petitioner The League of Women Voters of Rockford, Illinois.
This petitioner is a public interest organization whose purpose is to promote the active and informed participation of citizens in government and to act on seiected governmental issues. All 157 members of this petitioner live in Rockford, Illinois, which is located 16.8 miles from the Byron Nuclear Plant.
The petitioner is petitioning to intervene because of the League of Women Voters National Position on 6nergy which states,in part,that,
" Reliance on nuclear fission (light water reactors) should not be increased. Special attention must be given to solving waste disposal and other health and safety problems associated with this energy source.", and "Public understanding-and cooperation are essential to the success of any national energy strategy. Citizen participation
.:1e in decision making must be assured at every governmental level."
o" Interests to Be Affected e
eo The petitioner's interest and relevancy of concern in this proceding is with potentially serious ef fects on the health and safety of it's members and the general public, as well as serious environmental risks that may be caused by unresolved safety and environmental problems connected with operation of the Byron Nuclear Plant.Unless generic and
other safety and environmental problems are adequately resolve 7
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prior to plant operation, they will increase the probability of serious accidents, increase operating costs by f requent shut downs for repairs, increase releases of radioactivity above safe levels for Byron plant workers and the public, including residents of Rock-ford, Illinois, and cause longerm environmental problems.
Specific aspects of the subject matter of the proceedino as to which the petitioner wishes to intervene Specific problems not adequately considered at other hearings which pose significant safety and environmental hazards that must be resolv-ed prior to operation 'of the plant:
4 Generic safety problems which include, but are not limited to:
Plant design using a non-optimum turbine orientation which can cause danage to essential systems by turbine missiles.
Problems with degredation of stainless steel steam generator tubes.
54 smic qualification of safety related electrical equipment, as well as environmental and safety qualifi, cations of other safety re-lated equipment.
Serious impact' f orce;cntf ae.l' a.ssembly spicer grids caused by asymetric loads during blowdown following loss of coolent accident which raise a question of the reactor core having a zoolable geometry.
Adverse interaction between non-safety control systems and safety related protection systems in integrated protection system.
Fuel handling accidents inside the containment which are an un-reviewed safety question.
- 2. Spent fuel compaction. The applicant in it's original application did not specify a compaction of the spent fuel pool with high densi ty racks.
Compact racks mean additional spent f uel assemblies in closer con-fuel pool figuration and an increase in the possibility of a spent accident.
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The NRC has not done a safety analysis or accident hazards analysis for compact spent fuel storage and it's environmental impact state-ment has not been completed.
from The question of decommissioning and removing the spent fuel the site has not been addressed.
The burial site for low level wastes produced by the spent fuel pool has not been specified.
- 3. Class 9 accidents have not been adequately considered, as recommend-
. ed by t'e U.S. Departmenrof the Interior in comments on the Final h
Environmental Statement of 1974.
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- 4. Serious seismic related site problems found af terh,the Final Environ-rmental Impact statement are related to:
the site a, Discovery of the major Plum diver Fault Line closer to and discovery of f aults af ter excavation than the Sandwich Fault,,
which lie directly under the Reactor containment an.d Fuel Handling Buildings.
to show time of most recent b, Failure to use the strain gauge test movement of these f aults and f ailure to follow them of f the site leave unanswered questions.
There is inadequate assessment of the need to upgrade the seismic qualifications of the site; :thit.should include review of a.the value for the Safe shut Down Earthquake and the Operating basis Earthquake because of the possibility of long term radio-
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and activity at the site due to lack of plans for d6comissioning, present pla'ns for long term storage of waste ;1:cluding spent fuel rods; this makes the calculation of a MMVI earthquake once in 2150 years an unacceptable long term risk, particularly in view of the fact that the '.last earthquake of MMVI occu red in 1972 with an epicenter about 30 miles from the plant si September,
- b. need for upgrading to Category I design all stuctures which
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r, have a potential for radiation release, including especia1Ty the radwaste building.
an earthquake.
- c. Effects of grouting on ground stability in
- d. Effects of construction of.large parts of the plant foundation below the water table.
- 5. Evacuation plans are not adequate and the cost has not been fully assessed. There are special problems in the 5 and 10 mile areas around the plant due to large temprary populations at recreational facilities., and the cost has not been fully assessed.
6.The applicant has not adequately addressed. e~ffects on the Rock River, gga va Am ometia<g including build up of tritium 4 effects of withdrwal of 30 million gallons of water a day as related to decreasing rainfall in the area and dropping ground water level, which may mean use of river water for drinking; water quality, and use of the river for recreation.
7 Containment of Krypton 85 is not being used by the applicant although the technology for a 99% aontainment is available. Krypton 85 poses along term residual risk becaue it is a carcinogen with a radioactive life of over 200 years.
- 8. Effects of radiation levels on plantrworkers;ppfticul. arty temppPary workers exposed to high doses of radiation, and people outside of the plant boundry who will be exposed to radiation from several nuclear plants through overlapping radiation areas has not been adequately addressed. Ney evidsoce;sbows low levels of radiation are much more harmfull than considered when the Final snvironmental statement was produced.
- 9. Full impact of powerlines, including radiation and production of ozon one of Illinois' most serious air quality problems have not been adeq-ately considered.
In addition the Applicant has not shown that there is a genuine need j
for the power to be produced by the Byron Plant. Also tne ppplicant
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t has not provided sufficient information to demonstrate that taking into account all health, safety and environmental considerations and alternative courses of action available, such as increased energy conservation and use of solar energy, the benefits of the plant out-weigh the costs.
For all these reasons, the Petitioner concludes that an operating license should not be granted to the Applicant until all the above mentioned issues are satisf actorily resolved.
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Respectfully,
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Betty Johnson, chairperson of the Natural resources and Energy Committees of the League of Women voters of Rockford,Ill 1907 Stratford Lane Rockford, Illinois, 61107 Da ted, January 13, 1979 s
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