ML19326D660

Motion to Admit TMI-related New Contentions & to Reopen OL Hearing.Consequences of Significant Hydrogen Release in Westinghouse Containment,Were Not Subj of Adversary Proceedings.Contentions & Certificate of Svc Encl

ML19326D660
Person / Time
Site:	Mcguire, McGuire
Issue date:	06/09/1980
From:	Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19326D656	List: ML19326D655 ML19326D660
References
NUDOCS 8007030040
Download: ML19326D660 (6)

Text

- . ..

4 e' ~

UNITED STATEJ OF AMERICA g

W "

r' NUCLEAR REGULATORY COMMISSION gi 3N ~

. [ BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

~

0 og & "E O N In the Matter of ,

) g

) 4 DUKE POWER COMPANY _ ) Docket Nos. 50-369 r' ) 50-370 McGuire Nuclear Station Units 1 and 2 )

CESG'S MOTIONS TO ADMIT I!EW COUTENTICIIS AND TO REOPEN THE MCGUIRE OPERATING LICEMSE REARIiiG The events at Three Mile Island 2, commencing March 28, 1979, have demonstrated that, at the time of licensing TMI-2 to operate there were still lessons,to be learned'. The McGuire construction

, permit and operating license proceedings were held before this date.

There is, further, the reasonable likelihood that there are additional lessons to be learned in the case of a TMI-2 type of accident involving hydrogen release and rapid combustion in a pressure suppression station such as McGuire.

Accordingly, CESG herewith moves the admission of new contentions which concern matters not previously subject to adversary proceedings:

the consequences of the combustion of a significant hydrogen release in a Westinghouse pressure suppression containment including contain-ment rupture, effects on health and safety of gaseous and particulate releases, emergency response, and long term population displacement and relocation. -

" "UL' N " la in""o"*.2 D:vsn a 0 s!3Eco YSATIQ? 3HT C Dmo l Contingent on the admission of CESG's new cont +Jttikorttt,3;fg4;fr moves the reopening of the McGuire Operating License'he+ frig'%is

' mv6 l , Report of the President's Commission on The Accident at Three -Mi:Lh.u - I Island, U.S.G.P.O.: 1979 0 - 305-557. .

s .... . o. ; ress .

Three Mile Island - A Reuort to the Commissi6ners and~to the Public g l NUREG/CR-1250 Vol. 1 TMI-2 Lessons Learned Task Force - Final Reoert,-EUREG-0535;.-

8007030&/8

+

appears to be required both from a consideration of the public interest, there are approximately one million people within a thirty i

mile radius of McGuire, and of the Applicant's interest. Duke Power '

Company has recently requested the Board to lift the stay it inposed on its Initial Decision . If the stay is removed, CESG, in the ambit permitted by an Appeal Board Order to file exceptions ,3 will so proceed. In view of the recent reconsideration of the immediate effectivenes's rule b , there is a reasonable likelihood that the Appeal Board will reopen the Operating License proceeding, staying the effectiveness of the Initial Decision. So viewed, and l

recognizing the time usually required.for each added step in the l litigative process, it favors Applicant's interest to commence -

proceedings with a minimum of preliminary steps.

CESG's six new contentions are attached.

Respectfully submitted,

}& -

esse L. Riley resident, Carolina Environmental Study Group At Charlotte, N.C.

June 9, 1980 Motion to Terminate Stay on initial Decision, May 30, 1980 3

The instant Initial Decision is viewed as interlocutory, ALAB order, June 21, 1979.

b k4 Fed. Reg. 65049 (November 9, 1979).

.~.. 1: , _ :- . .. - . -.

~

~

an **

CESG CONTENTIONS 1 The granting of an operating license for McGuire Units 1 and 2 will cause the public to be exposed to unacceptable risks to health, safety and property in th,at the Westinghouse pressure suppression type containment, designed for a 15 psig pressure differential, can be exposed to significantly higher pressure differentials in the explosion or deflagration of hydrogen released in a Three Mile Island-2 type of accident.

2. The rate of recombining hydrogen is such that.a rapid and large hydrogen release like that at TM1-2 will cause the hydrogen con-centration in the containment to exceed the lower explosive limit' for appreciable periods of time.

3 Consideration has not been given to the consequences of a hydrogen explosion inside the reactor resulting from the flow of containment atmosphere into the reactor in cooling the core after a sequence in which, as at TM1-2, the ECCS system was turned off.

4 Consideration has not been given to the environmental, and safety and health consequences of simultaneous explosions in the reactor

'and the containment in terms of the release from the breached con-tainment not only of radioactive gases and volatiles, but also of radioactive particles which are both respirable and ground contam-inating.

5 In emergency evacuation planning consideration has not been given to a containment burst accident, accompanied by the release of gases and volatiles and, depending on the specific circumstances,,

of radioactive particulates.

w

- . t *

-2

/

L'#

1. ' 6.

L There has been no crisis relocation planning in the event of an accident involving containment burst, significant radioactive particulate discharge, and long term soil and water contamination.

The population in the vicinity of the plant is such that population relocation can generate costs far in excess of any economic benefits from the plant.

The CAROLINA ENVIRONMENTAL STUDY GROUP Charlotte, N.C. -

June 9, 3960 -

6

[

6 e

O

,, - , , e - , - - -

/ UNITED STATES OF AMERICA

/ ' NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

DUKE POWER COMPANY ) Docket Nos. 50-369

) 50-370 (William B. McGuire Nuclear )

Station, Units 1 and 2) )

AFFIRMATICU OF SERVICE I hereby affirm that copies of "CESG's Opposition to Motion to Terminate Stay of initial Decision, "GESG's Motions to Ac'mit New Contentions and to Reopen the McGuire Operating License dearing,"

and "CESG Contentions," dated June 9, 1980, in the captioned matter, have been served'on the following by deposit in the United

, States mail this 9th day of June.

Robert M. Lazo, Esq. Edward G. Ketchen,'Esq.

Chairman, Atomic Safety and Counsel for NRC Regulatory Licensing Board -

Staff U.S. Nuclear Regulatory Office of the Executive Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Dr. Emmeth A. Luebke Washington, D.C. 20555

. Atomic Safety and Licensing Board William L. Porter, Esq.

U.S. Nuclear Regulatory Associate General Counsel Commission Duke Power Company Washington, D.C. 20535 Post Office Box 2178 Charlotte, North Carolina 28242 Dr. Cadet H. Hand, Jr.

Director Chairman Bodega Marine Laboratory Atomic Safety and Licensing of California Board Panel Post Office Box 247 U.S. Nuclear Regulatory Bodega Bay, California 94923 Commission Washington, D.C. 20555 J. Michael McGarry, III, Esq.

Debevoise and Liberman 1200 Seventeenth Street, N.W.  %

Washington, D.C. 20036 e 9 *

= p\

E S

, %* dt f

. e

, 4 kJ -

i , ,

2 --

./

._ -9 Chairman, Atomic Safety and Chase R. Stephens Licensing Appeal Board Docketing & Service Section U.S. Nuclear Regulatory Office of the Secretary Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 1

?

- Jesse 1. iiile-J ._

w

.f ,

l

_ . . - , ,.- -, _ ,-