ML19305C555
| ML19305C555 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/03/1980 |
| From: | Markey A, Sekuler S, Wolff G ILLINOIS, STATE OF |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML19305C552 | List: |
| References | |
| NUDOCS 8003310045 | |
| Download: ML19305C555 (4) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BC?.RD IN THE MATTER OF
)
)
4 COMMONWEALTH EDISON COMPANY
)
Docket Nos. 50-295
)
50-304 (Zion Station Units 1 and 2)
)
)
FOL Nos.
DPR-39 (Storage Pool Modification)
)
DPR-48 EXCEPTIONS OF THE STATE OF ILLINOIS TO INITIll DECISION The State of Illinois (Illinois) takes exception to the Atomic Safety and Licensing Board's Initial Decision of February 14, 1980 and states that the Board erred in making the following findings and rulings:
,1.
That there was no reasonable basis for the testimony that a loss of coolcnt accident might occur in the spent fuel pool through neglect.(Initial Decision at 44).
2.
That there are sufficient sources of makeup water and adequate access to such sources to ensure that the public health and safety is not endangered by boiling in the spent fuel pool.
(Initial Decision at 45).
3.
That swelling of the tubes in the spent fuel storage racks due to accumulation of entrapped gas between the boral and thE5 stainless steel tube should not occur at Zion.
(Initial Decision lat 52).
4 soossio W 5
. 4.
That swelling of the boral caused by hydrogen gas production should not occur in the Zion racks.
(Initial Decision at 52-53).
5.
That swelling of the boral caused by corrosion product build-up will not interfere with the movement of fuel within storage tubes.
(Initial Decision at 53).
6.
That the surveillance program that Applicant has committed to institute will adequately detect corrosion, loss of neutron absorber material, and swelling of the storage tubes.
(Initial Decision at 55, 63).
7.
That intergranular stress corrosion cracking is not likely to occur in the proposed fuel storage racks.
(Initial Decision at 62).
8.
That a corrosion surveillance program need not be made the subject of a technical specification or condition of a license.
(Initial Decision at 63).
9.
That a dummy fuel assembly test of each tube on receipt of each rack need not be made the subject of a technical specification or condition of a license.
(Initial Decision at 69).
10.
That there need not be a technical specification or condition to a license providing that if any boral plate is
'ssing from-a tube, that tube must be plugged to make it impossible to insert a fuel assembly, and all of the remaining tub <ss must be subjected to neutron attenuation testing.
(Initial Decision at t-i 71).
. 11.
That in situ neutron attenuation testing need not be-made the subject of a technical specification or condition of a license.
(Initial Decision at 71-73).
12.
That the issue of groundwater monitoring is beyond the scope of this proceeding.
(Initial Decision at 95).
13.
That groundwater monitoring need not be made the
~
subject of a technical specification or condition of a license.
(Initial Decision at 95-96).
14.
That there is no need to change the Applicant's Emergency Plan due to the proposed modification and subsequent operation of Zion Station with increased spent fuel storage capa.lty.
(Initial Decision at 80).
15.
That the written testimony and attachments of Peter J.
Cleary be excluded from the record.
(Hearing Transcript at 1610).
Respectfully submitted, e
t fSV\\j\\l S' W l
SUSAN N.
SEKULER Assistant Attorney General Environmental Control Division 188 West Randolph, Suite 2315 Chicago, Illinois 60601 (312) 793-2491 EORGE WM. WOLFF l
Chief, Environmental Control Division ANNE K.
MARKEY Assistant Attorney General Environmental Control Division 180 West Randolph, Suite 2315 Chicago, Illinois 60601 (312, 793-2491
. g... :
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD IN THE MATTER OF
)
)
COMMONWEALTH EDISON COMPANY
)
)
(Zion Station Units 1 and 2)
)
Docket Nos. 50-295
)
50-304 Proposed Amendments to
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Increase Spent Fuel storage
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Capacity (43 F.R.
30938)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Exceptions of the State of Illinois to Initial mcisien" Da the above-captioned proceeding have been served on the following by deposit, first class, in the United' States mail, 160 North LaSalle Street, Chicago, Illinois 60601, this 3rd day of March, 1980.
Joan Wolf, Chairman Docketing & Service Section Atomic Safety & Licensing U.S. Nuclear Regulatory Board Panel, U.S. Nuclear Commission Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Forrest J. Remick Fuchael Miller, Esq.
305 E.
Hamilton Avenue Philip P.
Steptoe, Esq.
State College, Pennsylvania Isham, Lincoln & Beale 16801 One First National Plaza Chicago, Illinois 60690 Atomic Safety and Licensing Board Atordc Safety & Licensing U.S. Nuclear Regulatory Appeal Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Richard Goddard, Esq.
Steven Goldberg, Esq.
- r. Rick Konter Office of the Executive Legal Director 617 Piper. Lane Lake Villa, Illinois 60046 U.S.
Nuclear Regulatory Commission Dr. Linda W.
Little Washington, D.C.
20555 Member, Atomic Safety & Licensing Board Panel 5000 Hermitage Drive
.Raleigh, NC 27612
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% -t SUSAN N.
SEKULER