ML20008G157

Amended Sunflower Alliance,Inc,North Shore Alert & Citizens for Safe Energy Petition for Intervenor Status.Contentions Set Forth in Original Petition Are Adopted by Ref.Svc List Encl

ML20008G157
Person / Time
Site:	Perry
Issue date:	05/08/1981
From:	Lodge T, Wilt D CITIZENS FOR SAFE ENERGY, SUNFLOWER ALLIANCE, WILT, D.D.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8107020371
Download: ML20008G157 (8)

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UNITED STATLS OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OP:

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DOCKET NOS.

50-440-OL

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50-441-OL CLEVELAND ELECTRIC ILLUMINATING CO.

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ET AL

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May 8, 1981 (PERRY NUCLEAR POhER PLANT, UNITS

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ONE AND Ti.0)

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AMENDED PETITION OF SUNFLO'.ER ALLIANCE. ET AL Now come Sunflower Alliance, Inc., North Shore Alert and Citizen's for Safe Energy and, pursuant to the order of the Atomic Safety and Licensing Board, file this Amended Petition to further identify themselves.

Now come the remaining parties, who have already been granted intervenor status by the Atomic Safety and Licensing Board, and amend their original petition and set forth additional contentions. The contentions set forth in the original petition are hereby adopted in this Amended l

Petition by reference.

Daniel D. kilt, Esq.

Attorney for sunflower Alliance, et al 7301 Chippewa Rd.

Brecksville, Ohio 44141 216-526-2350 PROOF OF SERVICE The undersigned certifies that a true copy of this Amended Petition has been sent to everyone on the attached service list by regular United States Mail on this day of May, 1981.

.,t1 7s Daniel D. ' Wilt, Esq.

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l AMENDED PETITION IDENTITY OF SUNFLO,ER ALLIANCE INC., NORTH SHORE ALERT AND CITIZENS FOR SAFE ENERGY James McIntyre, President of Sunflower Alliance Inc. states that Sunflower Alliance, Inc. is a non-profit Ohio Corporation based in Jef ferson, Ohio. Mr. McIntyre lives in Jefferson, Ohio which is located within 50 miles of the Ferry plant. Mr. McIntyre has been authorized by the Sunflower Alliance, Inc. to represent the Sunflower Alliance Inc. in these proceedings.

Christopher F. Hagan is a member of the Noren Shore Alert which is an unincorporated association of individuals most of whom live within 50 miles of the Perry plant. Mr. Hagan lives in Cleveland Heights, Ohio which is within 50 miles of the Perry plant and his f amily owns real property in Madison, Ohio which is within 10 miles of the Perry plant.

Thomas Kim Hill is a member of the Citizens for Safe Energy which is an unincorporated association of individuals most of whom live within 50 miles of the Perry plant. Mr. Hill lives in Lyndhurst, Ohio which is within 50 miles of the Perry plant and his family owns real property in Lake County, Ohio which is within 10 miles of the Perry plant.

James McIntyre for himself and for all other members of the Sunflower Alliance, Inc.; Christopher F. Hagan for himself and for all other members of the Northshore Alert; Thomas Kim Hill for himself and for all other members of the Citizens for Safe Energy asert that they and their organ-izations have the following interests in this proceeding:

1. they have an interest in and will be directly affected by any emergency evacuation plans adopted by the Applicant;

2. they have an interest in and will be directly affected by the decommissioning of the facility in that it will directly affect their use of their property located within 10 miles of the plant;

3. they have an interest in and will be directly affected by any determination made by the Nuclear Regulatory Commission that the theoretical design of the G.E. BWR/6 reactor and the Mark III containment are in fact valid,

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4. they have an interest in and will be directly.tructed oy tue the r cc tuut it u.s been demonstrated that the design of the sWn/6 reactor scram system is insufficient;

5. they have an interest in and will be directly affected by the fact that the GE BWR/6 could develope a leak in its piping system and there is no pethod for the operators to close off the leak;

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6. they have an interest in and will be directly affected by the fact that the entire safety system of the GE BWR/6 reactor is insufficient in that they live, work and own property with-in 50 miles of the Perry plant;

7. they have an -interest in and will be directly affected by the fact that Applicant's Final Safety Analysis Report (FSAR) has not adequatedly given consideration to the assessment of the social impacts of the transportation of nuclear wastes;

8. they have an interest in and will be directly affected by other factors that will be presented at the time of the final hearings on the application; For these reasons and for others to be developed later, the Sunflower Alliance, Inc. by and through James McIntyre; the North Shore Alert by and through Christopher F. Hagan and Citizens for Safe Energy by and through Thomas Kim Hill move for permission for leave to intervene in this p'roceeding.

M)DITIONAL CONTENTIONS Your intervenors, in addition to the contentions set forth in the

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original petition for intervention, incorporated herein by reference, add the following contentions to be litigated in these proceedings:

ELEVENTH GROUND OF INTERVENTION:

The GE BWR/6 is a prototype plant and the final testing to determine the satety of the plant has not been completed. Specifically, the following items have not been completely tested:

1. BLR/6 core spray distributions have not been finally tested;

2. A full scale 30 degree sector steam test has not been preformed;

3. The core spray and core flooding heat transfer effectiveness of the reactor have not been finally tested;

4. The Mark III containment structure has not been tested to verify the preformance of its pressure suppression design;

5. Critical heat flux testing has not been completed; TkELTH GROUND OF INTERVENTION:

It has been demonstrated that the cooling systems of GE BWR reactors are susceptible to cracks and corrosion. This can lead to a leak in the piping whic'.i the operators could not close in time to prevent a dangerous overheating of the reactor core. Proof that this problem has been corrected must be demcastrated before any license should issue.

THIRTEENTH GROUND OF INTERVENTION:

It has been demonstrated that the GE BKR scram system is not effective and modifications have been ordered by the NRC. Licensing of this plant should not be permitted without proof that the scram system contemplated for use at Perry complies with current regulations.

FOURTEENTH GROUND OF INTERVENTION:

The Perry plant is located near several small airports one of which intends to expand. The FSAR is insufficient in its analysis of the probabilities of an airplane crash into the containment structure. Applicant's estimates of the probabilities of such accidents do not tske into consideration a substantial increase in business air traffic projected during the 40 year operation of the plant. Thus, the plant should either be moved or in the alternative, since the containment structure has not been completely tested or built, strengthened to withstand the crash of the largest business aircraft that flies in the area.

FIFTHTEEh"rH GROUND OF INTERVENTION:

The applicant should be required to provide a redundant and diverse automatic shutdown system to mitigate the consequences of anticipated

, transients without scram. The FSAR indicates that applicant is not suffielently protected age. inst ATWS. It is now conceded tha; about 20 transients per year are typical of new reactors with about 6 transients per year typical after several years. Applicant's protection from ATWS is currently insofficient.

SIXTEENTH GROUND OF INTERVENTION:

Electrical wiring for Perry is susceptible to fast flaming with the potential result of failures throughout the plant in the event of

~ a fast and intense flash fire, SEVENTEENTH GROUND OF INTERVENTION:

It has not been established that the Mark III containment structure accounts for buckling. The final testing on the structure has not been completed. Further, it has not been established that the shell itself is strong enough to resist the dynamic and static loads which may occur during thr: 40 year life of the plant.

EIGHTEENTH GROUND OF INTERVENTION:

Problems have occurred with control rod ejection in several reactors recently. Applicant shotid be required to demonstrate that this problem does not exist in the BbK/6 structure and that it is impossible to occur.

l The plant must be adequately tested to demonstrate that unplanned with-l drawal will not occur.

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NINETEENTH GNOUND OF INTERVENTION:

Applicant's Final Environmental Impact Statement has not yet been

. filed. Therefore, it is impossible to state whether or not Applicant's plans as far as a cooling lake are concerned comply with the National Environmental Policy Act or the effects the operation of the plant will

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have on Lake Erie in terms of its fishing intustry and its availability for use as a recreational facility. Thus, these license hearings should be

. stayed until the Final Environmental Impact Statement is filed.

TWENTITH GROUND OF INTERVENTION:

The emergency core cooling system (ECCS) performance will be degraded by blockage of the ECCS pump suction line sotiners witu lusul. tion di. lodged during a loss of coolant accident. We contend that the Applicant's containment r

emergency sump pump will not function reliably because during a loss of coolant accident (LOCA) thermal shieloing and insulation may be ripped off or otherwise released or separated from in containment building piping where it would block off the drain of water, preventing it from being recirculated for cooling by the sump pump. This would degrade the ef fectiveness of the ECCS and gause injury to your intervenors.

WENTY-FIRST GROUND OF INTERVENTION:

The diesel generator which powers components in the high pressure core spray system and the diesel generators which power the rest of the plant are not reliable in automatic start-up and operation because they are identical to generators that have failed. See NUREG-0660.

TWENTY-SECOND GROUND OF INTERVENTION:

The indication of power operated relief valve and safety valve position to the reactor operators is ambiguous and unreliable, as demonstra:ed by TMI.

T'aENTY-THIRD GROUND OF INTERVENTION:

Applicant's stainless steel components, including safety system piping and nuclear steam supply system piping, will be coated and cleaned with compounds that could contribute to intergranular stress corrosion cracking.

TWENTY-FOURTH GROUND OF INTERVENTION:

Intervenors reserve the right to file further amendments during the licensing process as new information becomes available or as additional regulations and safeguards are imposed on nu: lear power plants by appropriate

authorities.

WHEREFORE, Petitioners pray that Sunflower Alliance Inc., North Shore Alert and Citizens for Safe Energy be granted Lt1ervenor status on all the grounds as stated herein; That all grounds as stated in the original petition and this amended petition plus any additional grounds that may be developed hereinafter be allowed as grounds during these proceedings; That this matter be set for such pre-adjudicatory and adjudicatory proceedings as the Commission shall see fit all with leave of Petitioners and In:ervenors to participate as full parties; That a hearing be granted to Petitioners and Intervenors with full participation by the Petitioners and Intervenors prior to the licensure of Perry Units 1 and 2; That by way of adjudicatory relief, af ter a full hearing, that this Commission deny operating licensure of Perry Units 1 and 2.

Daniel D. Wilt, Esq.

Attorney for Petitioners and Intervenors 7301 Chippewa Rd.

Brecksville, Ohio 44141 216-526-2350 and Terry Lodge, Esq.

Attorney for Petitioners and Intervenors 915 Spitzer Bldg.

Toledo, Ohio 43604 419-255-5058

J SERVICE IIST Peter B. Bloch, Chairman Dr. Jerry R. Kline Atomic Safety & Licensing Board Atomic Safu.;- 6 Licensing Boacd U.S. Nuclear Regulatory (Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Frederick J. Shon Jay Silberg, Esq.

Atomic Safety & License.3 asard 1800 M Street N.W.

U.S. Nuclear Regulatory Commission Washington, D.C.

20036 Washington, D.C.

20555 Charles A. Barth, Esq.

Donald T. Ezzone, Esq.

U.S. Nuclear Regulatory Commission Assistant Prosecuting Attorney Washington, D.C.

20555 105 Main Street Painesville, Ohio 44077 Todd J. Kenney Jeff Alexander 31800 Creekside Drive 920 Wilmirgton Ave.

Pepper Pike, Ohio 44124 Dayton, ti,lo 45420 Terry Lodge, Esq.

Docketing & Service Section 915 Spitzer Bldg.

Office of the Secretary Toledo, Ohio 43604 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 l

l Atomic Safety & Licensing Board Panel Atomic Safety & Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission l

Washington, D.C.

20555 Washington, D.C.

20555 l

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