ML20028E132
| ML20028E132 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/19/1983 |
| From: | Jay Dougherty CONCERNED CITIZENS OF LOUISA COUNTY, DOUGHERTY, J.B. |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-OLA-1, NUDOCS 8301210016 | |
| Download: ML20028E132 (9) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION trtElED r: h .
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In the Matter of j 'g3 jd 19 P254 VIRGINIA ELECTRIC AND POWER COMPANY ) Docker. Nos.
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(North Anna Power Sta,, Units 1 & 2) ) 50-33810L'A-l*~
) 50-339 OLA-1 (Proposed Amendment to Operating License )
to Permit Storage of Surry Spent Fuel) , )
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CITIZENS' REVISED CONTENTIONS The following is a list of the contentions that Con-cerned Citizens of Louisa Cour.ty (" Citizens") intends to advance in the above-captioned proceeding. Each conten-tion is followed by a summary of the factual basis for it. Those contentions that were lis,ted in Citizens' Pe-tition for Leave to Int'ervene, filed October, 22, 1982, should be disregarded henceforth, as they are superceded by those contentions listed herein.
Citizens has secured the assistance of two experts in the field of spent fuel transportation and storage:
Mr. Lindsay Audin of Ossining, NY, and Dr. Marvin Res-nikoff, of New York City. Both have written and spoken I
8301210016 830119 PDR ADOCK 05000338 0 PDR C '3/
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Together they have prepared an in-depth study of the
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economic, safety, environmental, and other aspects of spent fuel transportation and storage. This study will be published in book form in March, 1983. They have assisted counsel in the preparation of contentions, and intend to present testimony in sup, port thereof.
- 1. The proposed license amendment constitutes a major federal action significantly affecting the human environ-ment, and thus may not be granted prior to the prepara-tion of an environmental impact statement.
The transportation of spent fuel by truck creates ,
a risk of accidents causing tremendous human health and environmental damage. Although the NRC has promulgated standards, 10 C.F.R. Pt. 71 App. B, governing spent fuel ,
cask safety, these standards would not prevent serious consequences in the event of an accident. Moreover, these standards are outdated and unreliable.
( The 30-foot drop standard corresponds to the im-pact that would be sustained in a 30-m.p.h. collision.
l l Since, however, there is no reason to believe that i
VEPCO's spent fuel trucks will travel at less than 55-60 l
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i m.p.h., an accident exceeding NRC criteria is.quite i possible. Studies show that if a spent fuel cask were -
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to strike a bridge abutment sideways ~at no more than 12.5 m.p.h., the cask cavity could be expected to i rupture'. Batelle Pacific Northwest Laboratory, An Assessment of the Risk of Transporting Spent Nuclear )
Fuel by Truck, PNL-2588 (Nov. 1978) at 6-4. f Further, NRC fire standards are inadequate. More than 1.5% of all highway accidents involve fires. PNL-L
- 2588, supra. Many commonly transported substances, e.g.,
diesel fuel, burn at a temperature higher that the NRC's design basis fire temperature of 1,450 degrees. Indeed, many substances, e.g., propane, burn at 4000' degrees or higher. Moreover, highway fires in rural. areas can be-
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expected'to burn for more than the NRC standard of 30 4
minutes. Many transportation-related fires burn for hours ;
or days. An 1,850 degree-fire which burns for only 30 minutes can cause failure in valves essential to cask l integrity. !
i A hypothetical accident scenario analyzed by our
- experts for other purposes involves a single truck cask-
- which is involved in an accident in a rural area. They predict impacts including hundreds of cancer deaths per year for several years following the accicent, and economic damage ranging in the tens to hundreds of mil-lions of dollars. Whether impacts of this magnitude can
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be expected should one of VEPCO's shipments become in-volved in an accident has not yet been determined, but -
it is safe to say that roughly comparable results are probable.
Other environmental costs associated with the pro-posed license amendment include the risk,of sabotage, the effects of which would be comparable to those of -
a serious traffic accident. In addition, the possibility of error by VEPCO employees when performing such tasks as sealing the shipping casks creates additional risks.
Because of all of these risks, the proposed license, amendment involves significant environmental effects.
- 2. Applicant has not shown that the shipping casks to be used to transport Surry spent fuel to North Anna meet NRC standards.
10 C.F.R..SS71.35 and 71.36 require that all casks used for spent fuel shipments meet specific standards set out in Pt. 71 App. A and B. Noncompliance with these standards creates a great risk of harm to the public health and safety. If a noncomplying cask were involved in a routing highway accident it would be quite possible that the cask would rupture following impact or exposure to fire. Serous damage to the fuel rods within the cask
, would be quite possible. Thus,_ a large fraction of
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the volatile radionuclides within the fuel rods would -
be released to the ambient air, causing hundreds or tho.tsands of cancer deaths and extensive environmental damage.
The document (" Spent Fuel Storage") that was sub-mitted to the NRC by VEPCO in support of its license amendment application indicatesoonly that ".[t]he sp .t fuel cask used will have been approved and certified by NRC". Sec. 5.0 at 50 (emphasis added). Compliance with the applicable standards must be shown before the license amendment can be issued.
- 3. Applicant has not shown that there exists an emer-gency response plan adequate to protect the public health and safety.
The severity of an accident involving a spent fuel shipment depends on the steps taken by response author-ities. Essential to an adequate emergency:: response plan are proper equipment (e.g. , protective clothing, breath- "
l ing apparati, radiation monitors, communications equip-l I ment, cask lifting equipment), proper training of offi-l cials and emergency personnel, proper response proced-l l
ures, means of sharing information among agencies, ad-l l vance public education, and evacuation plans. NRC, i
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1 Survey of Current State Radiological Emergency Response
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Capabilities for Transportation-Related Incidents, NUREG- -
1620 (Sept. 1980). The fire fighting and emergency res-ponse personnel in the vicinity of the North Anna plant have little or none of the necessary equipment or train-ing. In support of its application VEPCO has stated only that it will have an emergency response plan, and that the plan's objectives will consist largely of assisting local response personnel. There is now no reason to be-lieve that any potential response authority, be it VEPCO or state or local agencies, has or will acquire the rud-imentary elements of an adequate emergency response plan.
Unless such a plan is put in place, the issuhnce of the requested license amendment will be inimical to the pub-
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lic health and safety and thus beyond the Atomic Safety and Licensing Board's authority.
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- 4. Neither Applicant nor NRC Staff has adequately con-sidered the alternative of constructing a dry cask storage facility at the Surry station.
Tha use of shipping-type casks for indefinite storage of spent fuel has been shown to be feasible. In the opinion of Mr. Audin and Dr. Resnikoff, dry cask storage methods are among the cheapest and safest of all spent fuel storage methods, including pool storage. Dry cask storage may well be safe and reliable for up to 50 years or more. In ad-
O g dition to its economic and environmental advantages,
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dry cask storage provides a capability for on-site as '
well as off-site transportation of spent fuel. E.R.
Johnson Associates, Inc., A Preliminary Assessment of Alternative Methods for the Storage of Commercial Spent Nuclear Fuel, (Nov. 1981) at 4-1. And in this case the construction of the dry cask storage facility at the Surry station would eliminate the need to transport spent fuel off-site.
VEPCO has already applied to the NRC for authority to construct such a facility at Surry. It cannot be determined at this time how long the NRC review process will take. Butevenifthefacilitycannotbbcompleted for several years, the safe operation of VEPCO's reactors will not be threatened. VEPCO claims that it is threat-ened with the loss of full core discharge ("FCD") capa-bility at the Surry spent fuel pool in 1984, and with the shutdown of one of the Surry units in 1987. These dates can be deferred schstantially .
First, VEPCO can install three spent fuel racks in the cask lay-down area in the Surry pool. In an internal VEPCO memorandum in Citizens' pos se ssion, this alternative is held out as presenting no prob 1cus from a technical standpoint. It is said to defer the loss of FCD capability by "at least two years . " Anot her m cmo in C it iz e ns ' posses-sion suggests that FCD capability can be extended by at least a ano ther ye ar by repl a cin g the stainless steel ra is now in the Surry pool with new, lighter ra cks equipped wit h
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-b neutron-absorbing materials. And, if necessary, a limited number of spent fuel assemblies could be shipped from Surry
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l to North Anna, so that the dry cask storage facility could be completed before a full transshipment program becomes necessary. Since FCD capability is not essential to safety, see Department of Energy, U.S. Spent Fuel Policy, Storage
- of U.S. Spent Power Reactor Fuel vol. 2 (May 1980) at 11-12, dry cask storage remains an attractive option even if it can't be implemented until roughly 1990.
- 5. Applicant has not shown that its physical protection system satisfies NRC regulatory requirements.
10 C.F.R. 273.37 provides that VEPCO, if it is to'shiptspent fuel from Surry to North Anna, must implement a security pro-I gram meeting a number of specific requirements. Compliance with these requirements is essential if the risks to public health are to be minimized. However, "all of the information l
concerning such security measures has been deleted from the available documentation on file at the NRC's public document l
l room. Citizens intends to review the adequacy of VEPCO's security plan, and assumas that means' can be devised for pro-tecting VEPCO's legitimste security interests.
Respectfully submitted, dames B. Doggherty L' Dated this 19th day of January, 1983 Counsel for Citizens 3045 Porter St., NW Washington, D.C. 20008 (202)362-7158
a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of
$ '83 JM 19 P2:54 VIRGINIA ELECTRIC AND POWER COMPANY ) Docket Nos.
(North Anna Power Sta,, Units 1 & 2) ) k:;50-33bTkIIEU-l
) 50E3 @ 0LA-1 (Proposed Amendment to Operating License )
to Permit Storage of Surry Spent Fuel) .)
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CERTIFICATE OF SERVICE I certify that copies of the foregoing CITIZENS' AMENDED CONTENTIONS were served this 19th day of January, 1983, by deposit in U.S. Mail, First Class, upon the fol-lowing:
Michael Maupin, Esq. Marshall Coleman, Esq.
Hunton & Williams Beveridge & Diamond Box 1535 1333 New Hampshire Ave., NW Richmond, VA 23212 Washington, D.C. 20036 i
Daniel T. Swanson, Esq. Sheldon J. Wolfe, Chairman U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Comm'n ,
Washington, D.C. 20555 Dr. Jerry Kline Adminiserative Judge Dr. George A.,Fergu. son
- U.S. Nuclear Regulatory Commission Adminis trative 'Jddge l Washington, D.C. 20555 School of Engineering Howard University l 2300 5th St., N.W.
l Washington, D.C. 20059 l
- 3 J&nes B. Douptierty W
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