ML19289E831
| ML19289E831 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/11/1979 |
| From: | Fontanta L, Larry Jones FONTANA, L., GILLESPIE & JONES |
| To: | |
| References | |
| NUDOCS 7905290151 | |
| Download: ML19289E831 (14) | |
Text
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M UNITED STATES OF AMERICA M.
NUCLEAR REGUL.5. TORY COMMISSION f[f d4,',
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BEFORE THE ATOMIC SAFETY & LICENSING BOARD f-C!
Q' In the Matter of LOUISIANA POWER & LIGHT COMPANY Docket No. 50-382 (Waterford Steam Electric Station Operating License Unit 3)
Application SAVE OUR WETLANDS, INC., AND OYSTERSHELL ALLIANCE, INC.
CONTENTIONS The original petition of Oystershell Alliance, Inc. and Save Our Wetlands, Inc. is hereby amended, pursuant to 10 CFR 2.714(b), by adding thereto the following contentions:
1.
Applicant has failed to demonstrate the necessity in the public interest for operation of the Waterford 3 Facility, based upon the following consider-ations:
a.
Applicant's assignment of higher than reasonable figures for projected demand for electric power which are current diminution of dema id for electricity on the order of 50% of past (i.e.1960's & early 1970's) demands for electric power.
b.
Applicant's assigni vent of industrial demand factors for electricity which neglect to give appropriate discounts for self-generated industrial power, which industries and other large consumers of power are resorting to in the face of high and increasing electrical costs.
c.
Applicant's overestimation of the costs of alternative fuels and energy sources such as, inter-alia, coal, geo-thermal, wind, solar and hydraulic (ocean current) sources.
d.
Applicant'.; assignment of greater than reasonable factors for reserve electrical production capacity requirements.
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Applicant has failed to demonstrate the necessity in the public interest.
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I for operation of tae Waterford 3 Facility based upon its understatement of i
costs of generating power at the facility which understatement of costs
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results from improper consideration of theJollowing factors:_.'._,._g _. h a.
Applicant.has, overstated the production capacity faEtor (i.e.
generating capability of the facility) because of design ihefficiencies and
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operating basis inefficiencies which are associated with the operation of pressurized water re:,ctor f?WR) steam generators.
These inefficiencies include generic problems associated with steam generators of the recirculation type, and steam generator degradation, as was recently noted in the Division of Operating Reactors recent March 2,1979 communication to applicant.
- b. Applicant has understated the costs of obtaining uranium fuels which will be used to operate the facility based upon its disregard for the escalation of the costs of such fuel, which can be reasonably expected to rise in cost to l
at least three times present cost.
c.
Applicant has understated the costs of decommissioning the facility based upon its reliance of industry generated data which fail to properly cost account for properly safeguarding against radiation waste releases,in view of present decommissioning expenses which indicate probable costs of decommissioning on the order of $500 million.
- d. Applicant has understated the short term storage costs of spent fuel
- by refusing to account for increases in costs associated wi'th requirements for expansion of spent fuel storage pool.
- e. Applicant has understated the costs of transferring spent fuel within the site by failing to acknowledge necessity for such activity, f.
Applicant has understated the costs of transferring spent fuel outside the site by failing to identify the carriers, methods or means or 04/
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V' permanent destination of such tr sfer.
- g. Applicant has understated the long term storage costs of spent fuel' -
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by its failure to specify means and methods for such long term storage.
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' Applicant has failed.to.demonstdiththe necessity in the public-interest-3.
for completion of the Waterfor.d 3 abity,.. based upo following
~ considerations:
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Applicant's-assignment.of higher.than ~ rgasonable figure.s for projected demand Er ere'ctric'p~ower which ignore current' diniinutioI of ~~
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demand.for. electricity on the order of 50% of past (i.e.1960's.& early 1970.'s)
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demand for.electr.ic power.,
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b., Afplicant's assignment of' industrial'demhiid factors for electricity 4-which neglect to give appropriate discounts for pelf-generated industrial *
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.; g power, which industries and.other. large consumers oY power are resorting to in the face of higher $ and increasing electrical costs.
c.
Applicant's overestimation of the costs of alternative fuels and energy sources such as, inter-allia, coal, geo-thermal, wirid, solar and hyd.mulic (ocean current) sources.
d.
Applicant's assignment of greater than reasonable factors for reserve electrical production capacity requirements.
4 Applicant has failed to demonstrate the necessity in the public interest for completion of the Waterford 3 Facility based upon its understatement of costs of generating power at the facility which understatement of costs results from improper consideration of the following factors:
a.
Applicant has overstated the production capacity factor (i.e.
gerating capability of the facility) because of design inefficiencies and
';vating basis inefficiencies which are associated with the completion of presurized water reactor (PWR) steam generators.
These inefficiencies include generic problems associated with steam generators of the f(j zt /
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recirculation type, and steam generator degradation, as was recqntly noted in
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the Division of Operating Reactors recent March 2g1979 comhunication to i*
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ik b., Applicant'lias understa:ted the ' costs of obtaining uranium fuels which
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,I wil4 be used to cgklete the facility based upon its_. disregard, for.ths
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p escalation of the costs of such fuel, which can be reasonably expected to rise r
in cost to. at least three t_imes present cost. -
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c.
Applicant-has uridEistated the costs of decommissioning-the facility based upon its reliance of. industry generated data which fail to prop,erly cost account ior' properly sa'feguarding against'rsdiation wasths refeases in view
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-Af-present decommissioning.eypenses which1 indicate probable costs of -
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decommissioning on the. order of $500 Million.
- d. - Applicant has undestated.the short term ~ storage costs of spent-fuel ' -
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by refusing to account for increases in costs associated with requirements.for expansion of spent fuel storage pool.
- e. Applicant has understated the costs of transferring spent fue! within the site by failing to acknowledge necessity for such activity, f.
Applicant has understated the costs of transferring spent fuel outside the site by~failing to identify the carriers, methods or means or permanent destination of such transfer.
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- g. Applicant has understated the long term storage costs of spent fuel by its failure to specify means and methods for such long term storage.
5.
Applicant has failed to demonstrate the necessity in the p%He interest 5
for enmpletion of the Water 3 Plant due to its assignment of unrealistic values to the projected demand for electric power.
6.
Applicant has failed to comply with 10 CFR 50.33 and Appendix C requk.-- : nts for the following reasons:
a.
Applicant has indicated in Exhibit 4 of its Application that it does f
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y not presently possess.the funds from earnings, borrowings or stock issues P.
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necessary to succeisfully complete the' facility.
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- b. Applicant has indicated in Exhibi.t 4'af its application that it cannot now obtain the funds by use of_. earnings,- borrowings, or stock issues necessary,..
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s to successfully operate 4he facilltpas; required by~10 CFR 50.33.
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- c. -Applicant.has not set forth in substantial particularity a reasonsbie r
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assurance of obtaining necessary funds from earnings, borrowings, or stock Issues as required by 10 CFR 50.33.
- d. Applicant has indicated an intention to rely upon construction work in progress awards (CWIP) 'in order to successfully complete,) operate and decommission the ficility. Precidentially, such awards have not been granted by the Louisiana Publ_ic Service Commission; and applicant lacks any
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, assurance whatever $dbtaining such awa'rds presently. ~'
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7.
Applicant has failed to appropriately consider in the Environmental Report, Section 5.2, et seg. the long term effects of low level radiation discharges, asserted to be in compliance with 10 CFR part 50, Appendix I, resulting from operation of the facility, storage of radioactive wastes and spent fuel transportation activities upon the following:
- a.. Aquatic life, plant, animal and bird life, native flora and native fauna which would be adversely impacted by such emissions.
- b. Human beings who would be adversely impacted by increased cancer rates and allied diseases such as heart disease and pulmonary disorders as a result of such emissions.
c.
Plant, animal and human food chains which would be significantly
- t+-red, damaged or adversely impacted by such emissions.
- d. Genetic damage which would be caused by such emissions.
- e. Genetic damage which would be caused by Waterford 3 emissions in combination with all other radiation sources within the Baton Rouge-New
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<, a tr m. :5 A ticant ha.s fai.!e:un p uperiy *: valuate the.he..!th and retyttdamental.
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. I ts frem <nsi.vinc inU w.i. ;al,- pe uedainica),
new d.-d w dn; and-a,;.x:nd-- sources. of. popc.nica e;:v.1 tirg,.in: cambinatiotr with, hw Ibvel a introhad inte J.e enviconment by operation of the Wate ' rt 1 a.d..,.
'lic.'nt im n!4d te poperly. c. :!uate synergistic aFa.ts of low levei
/.;cn in ecmoirmina.witti known and. suspected carcinogens.such as t-nated hydrecarbons, other petrcchemicals, body. hormones, -tobaccon
' t..J otL similar substam.cs in the environment, vm.1 regarri to tne i,.,, a,.,.
F* ns. pvlatiensrwtach would be rendered more susceptibie to
..eart di ase, cr.c.fimva rular and,.ulmonary diseases.
Anim.1 and plarm. populations which will be adversely impacted
- c of envii nmental stresses induced by these combinatiens of factors.
'.oo'icant r as failed tcyproperly evaluate radiation emissions w'aich w!!!
4.
ited by ; rent fuel storage due to the underestimation of amount. c.f e iue. which will be held in storage ducir.g the usefullife of the facility.
V Applicant has failed to properly evaluate radiatiorremisdons which.wh!.._
e# by spent fuel storage by underestimating the amounts o' cper.: f.::!
iich will be processed,. handled and stored based upon underestimation.of -
- ' q..r.tity of such products-which will be stored orr site.at the faculty.
. '.,.glicant has failed to properly evaluate risks to humans. caused-by or.,c:a tion. of spent fuel and radioactive nuclear waster into and/or 2
S the Greater Metrcpolitan New Orleans Area as a result of ths n;:
Applicant'a lack of adequate.. details regarding: proposals for-
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- r- :occation of such materials.
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Applicant's failure to accurately evaluate radiation releases resulting f rom.such activityg e
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, 13. Applicant has failed to, appropriately. evaluate the hea,lth, safety and.
environmental risks.which result-from storage of the Waterford-3 site for an -
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extended and as yet undetermined length.of tim'e, of spent nuclear fuel naterials because of the lack of"an acceptable and technologically feasible and reasonable means for permanent and interim storage of high level i
radioactive wastes and spent fuel materials; which thus renders applicant's l
interim storage as d_e facto permanent storage.
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- 14. Applicant has failed to properly evaluate the spent fuel storage problem l
inasmuch as present inability to dispose of spent fuel assemblies will l
ultirr.ately result in the necessity of increased expansion of spent fuel storage facilities at the Waterford 3 site.
15.
Applicant has failed to provide adequate performance criteria for
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g radiation monitors utilized within the facility as regards redundency, f(
ecording, qualification and testing of post accident and incident monitoring.
Applicant has not, to dale, responded to this issue which was originally raised in Section 7.3 otthe Safety Evaluation Report for the facility.
16. Applicant has failed to realistically consider the consequences to the i
i environment, and to human health and safety, or the economic consequences of an occurrence, such as the problem which occurred recently at the 3 Mile i
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Island Facility near Middletowri Pbnnsylvania tesulting from the following:
- a. Breach of the reactor vessel.
- b. Breach of the primary cooling system.
- c. Breach of the containment vessel.-
17.
Applicant has failed to adequately make provision, according to the Emergency Plan contained in Chapter 13:3 of the FSAR, for the following emergency contingencies:
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a.
Evacuation of individuals located in the immediate vicinity of the c
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site, within St. Charles Parish in the event of a serious reactor incident.
b.' Evacuation of population masses'l'ocated within a 20 mile radius of the Waterford 3 cite in the event of a serious reactdr incident,' as was the 3 Mile Is!' nd Facility in contemplated during the recent crisis at a
- c. Storage of potassium iodine in locations which are readily accessible to affected individuals as protection against thyroid irradiation.
d.
Evacuation of low and middle income residents of the Greater Metropolitan New Orleans Area.
- 18. Applicant has failed to adequately evaluate effects on humans and on the environment and on the operational safety of the facility of the following consequences of assumed crack or pipe rupture events:
a.
Consequences of flooding of the containment vessel such as that experienced in the recent 3 Mile Island Facility crisis.
b.
Consequences of flooding of the Reactor auxilliary building under circumstances siroilar to that experienced in the recent 3 Mile Island Facility t
crisis.
- 19. Applicant has failed to provide workable solutions to problems of fuel element assembly guide near which is caused to fuel element assemblies by the difference in dbrability of the fuel element assembly guide tubes which are relatively soft and the cladding on the control rods which is a relatively hard wear surface. A'more complete discussion of this problem is contained in Staff Question 231.1.
- 20. " Applicant !$as failed to provide for comprehensive solid waste process control program by establishing acceptable process parameters such as pH, ratio of waste to solidification, temperature, etc. which will provide reasonable assurance of compliance with NRC requirements for complete 8
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solidification 'of wet wastes, as more particularly set' forth in NRC Staff i
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question 321.6.
- 21. Applicant has failed to appropriately evaluate the effects of maximum possible flood conditions upo'n the following:
Damage to water intake and discharge structures in the Mississippi a.
, River which could drastically curtail supplies of water required for ordinary plant operations.
- b. Damage to water intake and discharge structures which could curtail availability ot $ater supplies required for proper operation of safety systems.
I c.
Effects of physical isolation of essential personnel in the control room in the event of a medical emergency, resulting from closure of the primary entrance way into the containment structure.
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- d. Effects of lack of accessability of essential personnel in the control room in the event of an emergency requiring evacuation, resulting from closure of the primary entrance way into the containment structure.
- 22. Applicant has failed to discover, acknowledge, report or remedy defects in materials, construction and workmanship such as improperly poured and set concrete and concrete poured without required reinforcement during the fabrication of the contaihment vesse'1,(reactor vessel) and/or related integral I
systems.
- 23. Applicant has' failed to appropriately evaluate geologic activities within the vicinity of the plant, such as those described by Roger T. Saucier in the study ertitled "Recent Geomorphic History of the Pontchartrain Basin, i n risiana" published in U.S. Gulf Coastal Studies Technical Report No.16,
- , which activity could cause external flooding of the facility as well as
.u.hreaten the structural integrity of the fuel handling building, containment tcucture and reactor auxilliary building.
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- r Respectfully,
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~ LUKE FONTANTA 824 Esplanade Avenue New Orleans, Louisiana 70116 (504) 524-0028 9
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GILLES JONES B
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YM L. JONES, '
910 urity Home 6e d Bldg.
49 Veterans Me lyd.
Metairie, Louisia.
70002 (504) 885-5672 L
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- AFFIDAVIT OF NANCY HASKELL BEFORE ME, 'the undersigned, there did appear, NJ.NCY HASKELL, who kuly being placed on oath deposes and says:
- 1. That she is Secretary of Oystershell Alliance, Inc.
- 2. That her residence address is 2840 St. Charles Ave., New Orleans, Louisiana.
3.
That she is aware of the contents of the Contentions of Intervenors and attests that the information contained therein is true and correct to the best of his personal knowledge and belief.
f.
NANCY /lASKELL i
SUBSCRIBED AND SWORN before me, this day of A ril, 9.
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VOTA PUBLK MY COMMISSION iS FOR L E.
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AFFIDAVIT OF BRUCE KING BEFORE ME, the undersigned, there did appear, BRUCE KING, who duly being placed on oath deposes and says:
- 1. That he is Vice President of Save Our Wetlands, Inc.
2.
That his business address is 542 St. Peter Street, New Orleans, Louisiana.
- 3. That he is aware of the contents of the Contentions of Intervenors and attests that the information contained therein is true and correct to the best of his personal knowledge and belief.
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BRUCE KING SUBSCRIBED AND SWORN to before me, this /[
day of A
9.
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OThRY PUB 14IC
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191
> UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of LOUISIANA POWER AND LIGHT COMPANY v DOCKET NO. 50-382 (Waterford Steam Electric Station Unit 3)
CERTIFICATE OF SERVICE
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l hereby certify that on J
,1979, I ma' led copies of
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Save Our Wetlands, Inc. and Oystershell Alliance, Inc.'s Contentions of Intervenors to all individuals or entities appearing on the attached Service List, postage prepaid, first class in the United States Mail.
I also certify that a copy of the above and foregoing Amended Petition was hand-delivered to Applicant through their designated agent on the/
day of April,1979.
1
' ch YA N L. 3 ES, 2047 192
SERVICE LIST Sheldon 3. Wolfe, Esquire U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D. C.
20555 Dr. Harry Foreman Box 395, Mayo University of Minnesota 55455 Dr. Walter H. Jordan 331 West Outer Drive Oak Ridge, Tennessee 37830 Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Henry 3. McGurren, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C.
20555 E. Blake, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.
Washington, D. C.
20036 W. Malcolm Stevenson, Esquire Monroe & Lemann Whitney Building 625 Gravier Street 2h4/
lgj New Orleans, Louisiana 70112