ML19331C216
| ML19331C216 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/23/1980 |
| From: | Oneill J AFFILIATION NOT ASSIGNED |
| To: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML19331C215 | List: |
| References | |
| NUDOCS 8008140356 | |
| Download: ML19331C216 (6) | |
Text
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UNITED STATES OF AMERICA 7
NUCLEAR REGULATORY COMMISSION U-L
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3 *Je
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O' In the Matter of
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CONSUMERS POWER COMPANY
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Docket No. 50-155
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(Big Rock Point Nuclear
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Power Station)
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JOHN O'NEILL'S RESPONSE TO LICENSEE'S SECOND SET OF INTERROGATORIES j
Answering Licensee's Second Set of Interrogatories, John-O'Neill responds as follows:
1.
The intent of O'Neill Contention IIE-3 is to require the '
analysis of the possibility of criticality being reached in the proposed fuel racks, if the racks are not greatly damaged. It does not itself posit a scenario for a criticality occurring and thus IIE-3 excludes no possible chain of events leading to criticality, save those involving a gross distortion of the racks.
Therefore, Contention IIE-3 calls for an analysis of all events that vAu L could lead to criticality occurring in the pool with the modified racks _ Th. -
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fes.a,. the increased density of the racks would be a significant factor in any such potential accident. Accordingly, none of the following are excluded:
Water boiling away, water loss from the uneven distribution of l
plutonium in the fuel rods or bundles, cladding, deteriorating l
and causing cooling problems, loss of monitoring capacity, loss of off-site power, and equipment failure.
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For example, if criticality would not be achieved in the pool's existing racks if off-site power were lost, but could occur in the proposed racks if off-site power were lost, then the criticality is caused by the increased density of the racks. The applicant has not adequately analyzed the problem of criticality occurring in the spent fuel pool at Big Rock, if the racks are modified. Analysis of this issue becomes even more imperative when the presence of a significant quantity of plutonium in the fuel to be stored is considered.
(See enclosed clipping " Consumers Want Greater Plutonium Use at Big Rock".)
The application is inadequate because a) it fails to provide adequate experimental data for safe compaction (experimental as opposed to mere calcula-tions). There is insufficient experimental data for storage for a period of 20 years, which would be allowed by the proposed license amendment. There is insufficient experimental data on the compacted storage of mixed-oxide plutonium-uranium fuels;- b) it fails to consider and address the research and testimony of expert witnesses who have participated in other spent fuel pool hearings, all of whom warned of the increased dangers of criticality due to spent fuel compaction.
I include Dr. Richard Webb and Dr. Gordon Thompson and refer to i
number 290 German Report; c) the application fails to analyze sufficiently the effect of increased density upon proper cooling which is essentially re-lated to criticality. For example, in the event of cladding deterioration, the cladding material could block the flow of cooling water; d) the criticality analysis fails to consider the problems that have occurred in other spent fuel pools that have compacted fuel storage racks, including but not limited to the overheating and deterioration of cladding incident in the Montecello plant of Dairyland Co-op Wisconsin...
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2.
Dr. Gordon Thompson School of Engineering / Applied Science The Engineering Triangle Princeton, New Jersey 08544 Testimony of Dr. Thompson before the Energy Agency of the State of Minnesota on 10 May 1980 concerning the proposed increase of spent fuel storage capacity at Prairie Island Nuclear Plant.
Dr. Richard Webb (Address to be supplied)
Testimony of Dr. Webb regarding contentions regarding the accidental hazards and spent fuel etorage at the Salem Nuclear Power Plant in Salem, New Jersey and an analysis of the accident and hazards of storing highly radioactive spent fuel rods at the Zion Nuclear Power Plant near Chicago (PWR) (April 3,1979)
I affirm that the foregoing answers are true.
r JO 8 P. O'NEILL, II
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.. Consumers Wants w Me' Greater Plutonium 4
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.e Use at Big Rock Swy:, m j.
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J ACKSON (UPI) - Consurders Power
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Co. has asked the federal government to
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approve the use of plutonium, four times
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the current amount,in its Big Rock nuclear reactor.
The utility also wants permission to double the size of its stcrage facilities for highly radioactive nuclear waste there.
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Consumers has asked the U.S. Nuclear
& dot Regulatory Commission for approval to i
I store as many as 441 used atomic fuel assemblies on the site, near Charlevoix, an 7
I increase from the* current capacity of 193.,
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i If the NRC grants the request, the plant i
i also would be allowed the use of 150,
kilograms of plutonium a.1 fuel to replace some of the u~anium now used.
I The request is considered controversial
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because there are no permanent nuclear waste storage sites in the United States.
I Plutonium, a byproduct of uranium A
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fission reactions in nuclear facilities, is f%dg{
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When airborne, minute plutonium specks will cause lung cancer if inhaled.
CILARLEVOLT. Mich. (UPil-A leakage of ra-dioacth'e water last week at the Big Rock cucle-Meanwhile, non-radioactive steam and at p! ct here has conmeed sk'.e a:d local effi.
a loud noise blasted from the generating bedu es cust be changed 8
, system at the Cook plant in Bridgman when t.
t IT-a safety valve erupted, plant officials said.
State health officials said Mcnday that the Plant manager Del Shaller said the valve.
- ea age, posed no more danger than cu=erous blew about 7
- 30 p.m. Monday. The steam
' j,,,,I35,tn d]ts at Mich ar facilit poured out for about 20 minutes.
f!an in how such iscidents a e reported.
For example, they noted in a repert to Gov, f
Wilham G. MiIliken. Chcrlevoix County authos ties did not fearn of the leakage until,6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Q k( ]
t after it was discovered-and then only because of
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P one calls from reporters.
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"It's a scary setup." said Cid1 Defense Direc.
. tor Alice Tunison. I don't want to parf ceop!.
3 control.,,trying to keep my on stor.%eh' undN
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f7 but I'm IL v
14e Jager, chief endronmestal expert for the L
state Public Health Department, said his depart.
f ment **5 di5Ple85ed that the state was co im-(O @
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-mediately notiflad of the incident by Consu:ce a Power Co. of Jackson, which operates the pia:t.
CONSDIERS POWER and other etilities must notify the state of a problem at a rue' ear p!a::t only if it is a full-fledged emerge:cy requi:-bg implementatloc of the emer;;ency prepa.mbess pha I
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UNITED STATES OF AMERICA g
NUCLEAR REGULATORY COFD11SSION m.5 mm.=
In the Matter of
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CONSUMERS POWER COMPANY
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Docket No.(s) 50-155
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(Big Rock Point Nuclear Plant)
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CERTIFICATE OF SERVICE I hereby certify that I have this day served.the foregoing document (s) upon each person designated on the official service' list compiled by
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the Office of the Secretary of the Commission in this proceeding in accordance with the requirements of Section 2.712 of 10 CFR Part 2-Rules of Practice, of the Nuclear Regulatory Commission's Rules and
-Regulations.
E=E i==E E. 5 i".*.5
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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CONSUMERS POWER COMPANY
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Dccket No.(s) 50-155
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(Big Rock Point Plant)
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(Spent Fuel Expansion)
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SERVICE LIST Herbert Grossman, Esq., Chairman John A. Leithauser, Esq.
Atomic Safe'ty and Licensing Board Energy Resources Group 1
U.S. Nuclear Regulatory Commission General Delivery Washington, D.C.
20555 Levering, Michigan 49755 Dr. Oscar H. Paris Mr. John O'Neill, II Atomic Safety and Licensing Board Route 2, Box 44 U.S. Nuclear Regulatory Commission Maple City, Michigan 49664 Washington, D.C.
20555 Christa-Maria Mr. Frederick J. Shon Route 2, Box 108C Atomic Safety and Licensing Board Charlevoix, Michigan 49720 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ms. Barbara J. Godwin 306 Clinton Counsel for NRC Staff Charlevoix, Michigan 49720 Office of the Executive Legal Director U.S. Nuclear Regulatory Cornission Mr. Jim E. Mills Washington, D.C.
20555 Route 2, Box 108C Charlevoix, Michigan 49720 Judd L. Bacon, Esq.
Consumers Power Company Joseph Gallo, Esq.
212 West Michigan Avenue Isham, Lincoln & Beale l
Jackson, Michigan 49201 1120 Connecticut Avenue, N.W., Suite 325 Washington, D.C.
20036 Consumers Power Company
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Mr. David A. Bixel Philip P. Steptoe, Esq.
Nuclear Licensing Coordinator Michael I. Miller, Esq.
212 West Michigan Avenue Isham, Lincoln & Beale Jackson, Michigan 49201 One First National Plaza, Suite 4200 Chicago, Illinois 60603 Karin P. Sheldon, Esq.
William S. Jordan, III, Esq.
Sheldon, Harmon and Weiss 1725 I-Street, N.W., Suite 506 Washington, D.C.
20006
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