ML20040A476
| ML20040A476 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/16/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Mattson R, Thompson H, Vollmer R Office of Nuclear Reactor Regulation |
| References | |
| 811212, NUDOCS 8201210161 | |
| Download: ML20040A476 (1) | |
Text
%%
a DISTRIBUTION 40ecketM NRC PDR r-LB#4 Reading
~^
EAdensam Docket Hos. 50-413 MDuncan and 50-414 KJabbour RLTedesco EKetchen,0 ELD MEMORANDUM FOR:
R. H. Vollmer, Director, 31 vision of Engineering R. J. Mattson, Director, Division of Systems Integration H. L. Thompson, Acting Director, Division of Human Factors Safety S. H. llanauer, Director, Division of Safety Technology FROM:
R. L. Tedesco, Assistant Director for Licensing Division of Licensing
SUBJECT:
CONTENTIONS - CATAWBA ASLB HEARING As a part of our staff preparation for the forthcoming Catawba ASLB Hearing which will be contested, we have been provided with copies of amended petitions to intervene submitted by the Carolina Environmental Study Group, the Charlotte-Mechlenburg Environmental Coalition, and the Palmetto Alliance. Copies of these petitions are enclosed and are being distributed to each of your branches with a request for each responsible branch to review the petitions to determine technical validity, acceptability or rejectability (with basis), keeping in mind that the subject of each contention must be addressed in your input to the Catawba SER or EIS (your early notice). Also, the associated technical reviewer will be responsible to appear as a staff witness on the respective contention.
At that time, it will be too late to have NRR declare that we should have rejected the contention at the time it was submitted. We need your comments (annotations on petition copies is very acceptable) no later than Decenber 22 (keeping the llolidays in mind, can we try for December 18 - Friday?).
Your personal cooperation in assigning the required priority to your branches in meeting the above ( ASLB) dates is respectfully requested. OELD (E. Ketchen, X27502) and DL (E. Adensam, X27832) stand ready to provide assistance and guidance in completing this very important task that will have long tent consequences.
Robert L. Tedesco, Assistant Direct $ YJ.$
for Licensing
>U Division of Licensing
,g Qffp g ECx ~( @(,,[ 2
Enclosure:
As stated g
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nne FORM 318 @80) NHCM Om OFFICIAL RECORD COPY usom mi-us.
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TOz MIKE.MCGARRY fROM: AL CARR 6 pages
'U'iITED ST/,7-S OF AE'-.ICA NUCIE.G: F.~:.GUI 70hY CCXXISSIO;;
BE70RE THE ATO'~IC SAFE?Y Al D. LICE *S!!!G EDA 5.D In the Xatter of
)
)
DUES POWE~i COEPANY, et al.,
)
Dc ket Nos. 50-143
)
50-414 (Catawba Euclear Station,
)
Units 1 and 2)
)
CESG'S COI:TEXTIONS In accord with the Board's Order of Nov. 5,1951 CESG herewith a=c=:is its petition of July 27, 1961 and contendst 1.
The Board should dis =iss Applic=ntes Application for en Operating License.
The Catawba plant is not 5eeded now.
~
Both Applicant's and Staff's need forecasts made at the CP ntage have proved groncly defective m's to level of need and
'bD rate of growth.
CESG's forecast, in contrast, has proved O
$6Ab The earliest possible date of justifiable operation accurate.
of Catnuba is a decade hence, unless, es appects likely, greeh in ne'd decrences further.
A realistic, favorable, @.
~
e consideration is rescinding the CP and mothballing the plant t.ntil and unless the cost / benefit concideration for continuing, construction be ones favorable.
l 2.
The license should not in=ue until and unic s the
~
i
. :, /
. hydrogen release consequences fron that range and variety of I
Y l (,% ', ' LOCA's which the Applicant is required by the L~.4C to censider have.bcen dealt with so ?z to make inpossible damage to public
' health and safety,,
The igniter systen cennot perform this runction.
.3 The licensa should not issue because the risk evaluatien
%,6 r.ade by'the Sterf is inadequate.
fhe tetelity of risks, Da(=estazngnsp
1 4
y 2
including those demonstrated at TMI-2, in relation to the possiblo consequences for this specific sita, have not been i
operating i
considered.
The/ risks, plus those associated with deco::missioning, t
the transport, and both interim and long term storage of radioactive substances resulting fron generation, Fr.:st be taken into consideration in striking a cost / benefit balance vis-a-vis These risks are significant and grester by far alternatives.
I than those assuned at the CP stage.
It is not within the i
j capability of Applicant nor ERC to prove the absence of I
substantial risks to public health and safety over the period of ti=e which radioactive caterials forned by generation remain hazardous.
l 4.
. Motions by Applicant or Staff to di:=iss CESG as an
~
Intervenor should be denied.
The e are sufficient differences i
in the McGuire and Catsvba stations, and sufficient changes in
$Ab.
both the cost / benefit and safety cnd health --'tters for
., pt9 1
collateral estoppel or res _iudicata to be inapplienble.
[
>l
$..The license should not issue becau:e 'the cost / benefit
~ ~ ~ ~ '
SM state =ent was becene grosely eefective, slow'conntruction, eue b
Ogt princrily to Applicant's e'rroneously high forecast of" growth i
i l
in electrical de=and, will result in Catawba power being more j.
l; expensive than a number of alternatives, including conservation '
cnd renewable energy sources.
This has been de=onstrated by Applicantf a 10% increese in rate with declaring K:Guire, a plant si[milarly affected by elow construction, co=mercial.
6.
The lico:ise thould not i'ssue beceuse it will, contrary 3
intent of Cost [ benefit considerations, further burden 99.
to thS f
e
)
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........~.a.~,
~~....:.;T. :. 3ri: ~m 2 ^ = ~ ^^ ~
~=;L ja, the consumer, not 'only with construction costs 'and the interest.
on construction borrowing, but with an entirely undeserved '
carning on an unneeded facility.
The CP stage cost / benefit'.
statement is Grossly defective.
7 The Board should require the Staff to provide the
~ Environ = ental I= pact State =ent at least 90 days before the prehearing conference.
5his is essentini to permit CESG and other petitioners to take into consideration S tff ts views in~
regard to envircr$ ental and health" and atfoty mat,ters.
'Fhe existence of an EIS will aid the ' Board in its censideration 7
of the :.atters which should be at issue.
8.
If a license issues, it chould require that._ emergency.
.g/9 planning b'or the EPZ include the city of Rock Hill. ' Bcesuso the plant is a low pressure, ice conden er contain=ent type, andbecauset51econsequencesof=eversaccidentstreestinated to extend to at least 25 miles,'a radius of 30 ::iles should
?.
be the basis for energency planning.
This would include the
.~
city of Charlotte.
9.
The EIS should explicitly consider the consequences for the spoeific site of the entire spectrum of seri,ous release accidents, including Pk~d-1 to PWR-9 as for=ulated in the Reactor Safety Study.
This consideration should include the Sif d
recognition that local officials and resources are not qualified gC to assure protection of the public health end safety in the event of a serious accident.
10.
If a license issues, an adequate crisis relocation plan Tite nature of particulate Y'fLbshould be a condition for issuance.
releases in serious accidents, stich ss Tw3-1, is such th:t.
A-- - -
9 E
9 s
?
k_.s
-h-p..
g relocation of.the affneted population is ret. dred. Present plans
/ are deficient, in that no consideration is given crisis relocation.
9 F
i
,'Ihc operating license should not issue becauss part of '
'll.
gd{..,beconstructionwasnotcoveredintheC?andtheCPwas
,~
t amended without due process.
The fuel pool van greatly expanded
'by an anendnent.
The Inte'rvencr, CESG, was not, at the time, Enlargement of the fuel pool 'significantly,
apprised of this t increases.the source term for fuel pool accidents, including heiling dry followed by fuel acit.
- 12.. A license should not issue becance, since the CP stage, in respense to the me.ndates of North Carolina legislation, the
'.g&t
. applicant has c=b:rked on a vs.riety of progrn=s desi.gned to
.decreams' load growth such as Icad management, special. rates for conservers, und a program to assist hc=sowners in reducing thornal t
The cost / benefit statement of the CP stage was struck loss.
absent these censiderations.
The license sho(:1d not i: sue beesuse irregularities in 13 h.gb the welding practices on safety reinted systens endanger the L.-
public health end safety.
11;.
'Ihe prchenring conference should not be held until at JH 1 east 90 da'ys after the Safety Evaluation Repcrt has issued.
CESIG has concerns, reflected in sc=e folleving contentions, which :hould to cddressed by the SER.
Catauba.
15
'l:te 11censo should not issue because / was designed l
-.and is being constructed without appropriate consideration of electro =agnetic pulse.
EY2 vill knock out most of the never grids en which Applicant could rely fer bn=h.:p power, knock out l
~
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.__ k (_.. _ -. __... _....
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5..
,~
=oct if not all electronic and electric ce= r.:nications systens on which Appliennt routinely relies, knock out all control 1, systems relying on solid stRte conponents, knock out all co=puters including the off site co=puter used for nonitoring the ECCS thereby r.aking possible a variety of reactor accidents not forseen including the boiloff of water in the fuel pool.
16.
Tne license should not is:ue because the design of the
[
control ror= preceded knowledge of the essentini role of hu=an factors considarations in design, a factor in the TMI-2 accident and in other operatirsproblens having in conmon avoidable operator
\\
crror.
~
17 The license should not i= sue boccuse no consideration gf,b has been given to the effects of Cerbicule, known '. infest.the Catawba River and Lake Wylie, on the perforn:nce of the cooling
' aver syntas.
18.
The licen=e should not iseus beekuse reneter degradation in the form of a nuch more rapid increase inreference -tenperature D
-athan.had. been anticipated has occurred at a nu.ber of PW s
. including Applicant's Oconee unit 1.
Until and unless the ERO.
nbd the industry can avoid reactor embrittlenent, Catawba should not be pernitted to operate.
19'.
The license.should not issue until and unless the i
@g*b loosening of reacter nautron shield bolting and the loss of i
auch bolts in understodd and prevented.
Dropping of the neutren l
ch'ield frei its nupport, RESAR Fig.1.2-7, would result in 4
blockage of the coolant system riou path and, despite the 1
- ,.,.__ _ 4..._..
t k
20.
The license should be withheld as no provision has,been rade for the release'of substantial ancunts of'radioactivit'y to 6, Lake Wylie, the source of potable water for =any down stream h
ec:=unitie s.
Such a loss c=n occur in an cecident such as happened at Ocones, in which the quantity of r2dio[ective water resulting fron washing down a contaninated area exceeded the I
holding capacity, er from any one of a variety of as yet -
unen ountered operational errors.
21.
The license should not issue because Applicant's Environmental Report is deficient in that it does not consider the henith effects of tritiu=, considers only sirborne volatiles as a cource of dosage, ignoring water pathways, and does not
' consider the consequences of the release of radioactive i
particulates.
22 The licensenheuld not issue because the dilution of ownership was not considered at the CP stage and presents a series of problems in connection with responcibility cr.d lisbilitta.
A 755 interest in Catawba has niready been sold, It is Applicant's int'ention to dispose of the re ainder.
As the terrs of purchase era unfavorable to the buycra unless Applicant's unrealistic forecast of snies eventuates, the owner.s of the plant. vill be unable to neet the burdens of cunership, including a proper c=sumption of liability.
Recpectfully submitted, p
g' vhlt 4.
n ole sse L. Biley,/presicent,
~
Carolina Enyttil. Study Gr'p."
' 854 Henley ' Place na Charlotte, N.C.
2 207 I
70!4-376-14342 704-554-3143
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I
i
~
l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
+
t
=
i t
f In the Matter of
)
Docket Nos. 50-413 g
)
50-414 9
)
)
December 9, 1981 (Catawba Nuclear Station, Unit 1 and 2) )
1 d
PALMETTO ALLIANCE SUPPLEMENT i
TO PETITION TO INTERVENE i
a i
a Pursuant to 10 CFR Section 2.714 (a) (3Xb) and the Board's Order 4
of November 5, 1981, Petitioner Palmetto Alliance hereby files this Supplement to its Petition to Intervene listing the contentions which it seeks to have litigated in this matter, and the bases therefor, fully reserving its right to amend or expand this filing on the basis of information not now known to Petitioner, such as may be contained in amendments to the Applicants' Final Safety i
b Analysis Report, Environmental Report, or Application, or in the t
j
' Commission Staff's Safety Evaluation Report or. Environmental Statements, which have yet to be filed in this proceeding; or
(
for other good cause as provided for by 10 CFR Section 2.714 (a) (1).
6 Should the Board construe any of these contentions as an attack upon r
any rule or regulation of the Commission, or any provision thereof, j
i Petitio'ner requests that such rule or regulation be identified 1
and that Pe'titioner be permitted to seek an exception to or l
l i
5 i
n m.
I.
vaiver of the application of such rule or regulation with respect 4
l to this particular proceeding.
Petitioner Palmetto Alliance would respectfully show that the Application for the necessary licenses to own, use and operate the utili=ation facilities known as the Catawba Nuclear Station, Units 1 and 2, should be denied or appropriately conditioned since the grant of such licenses would contravene the National Environmental Policy Act of 1969 (NEPA), Pub. L.91-190, 42 U.S.C.A. Section 4332, where the environmental costs will outweigh the economic, technical r
or other benefits, new and additional information now being available which alters the consideration made at the Construction Permit stage for the facility; and the requirements o'f 10 CFR Section 50.57 can not be met where the Applicants can not demonstrate that the facility has been constructed in conformity with the construction permit, that it has been constructed and will be operated in conformity with the Application, the Atomic l
Energy Act, and the rules and regulations of the Commission; the l
Applicants are not technically or financially qualified to enga~ge in the activities for which they seek licensing; and there is a lack of reasonable assurance that license activities will be f
conducted in compliance with Commission regulations or that such activities can be conducted without endangering or being inimical i
to the health and safety of the public; in support of which Petitioner Palmetto Alliance would contend:
l 5
u
n.
1 1
The long term somatic and genetic health e'ffects of radiation i
h [huranium fuel cycle even where such releases are within existing-j releases from the facility during normal operations and from the t
g.
guidelines, have been underestimated by Applicants and Staff.
The work of K.
Z. Morgan, Bernd Franke of Heidelberg, and others calls into serious question the analysis relied upon including 1
that of the BEIR III report and the Commission's food chain analysis, strongly suggesting that the health effects of ionizing
}
radiation have been seriously underestimated.
=
2 The Applicants aid Commission Staff have failed to adequately
/ h assess the impacts of a serious accident at the facility, beyond g6 design basis.
The probebilistic analysis employed in the Reactor 4fb Saf ety Study (WASH 1400) has been so seriously criticized as.to make its use in licensing, proceedings as a basis for decision-making entirely inappropriate.
"The consequence model used in'-
WASH 1400 should be substantially improved, and its sensitivities explored, before if is used in the regulatory process."
NUREG CR 0400, " Risk Assessment Review Group Report to the U.S. Nuclear Regulatory Commission, H.W.
Lewis, Chairman," p xi.
Ths design f
of this facility differs from that of the reference reactor l
l considered in WASH 1400 in such significant manner as to adversely l
l af fect the probabilistic risk assessment employed in that study and relied ~upon by Applicants.
" Reactor Safety Study Methodology
b
-4
- 3 1
I r
Application Program:
Sequoyah flPWR Power Plant," NUREG CR 1659/1 of 4 (February 19 81), ER-OL 7.1-1.
Environmental consequences' l
of serious accidents specifically including "(H)ealth and safety j
risks" and "(S)ocioeconomic impacts that might be associated 1
1 with emergency measures during or following an accident should 4
also be considered" in the environmental impact consideration in licensing.
" Nuclear Power Plant Accident Considerations Under l
the National Environmental Policy Act of 1969, Statement of e
1 Interim Policy", 45'FR 40101 (June 13, 1980).
3 The Applicants have not provided reasonable assurances that
)
adequate measures can be taken in the event of a radiological emergency as recuired by 10 CFR Section 50.47 and Appendix E, by including in the plume exposure pathway EPZ for the facility at least the communities of Charlotte, NC, Gastonia, NC, and all of Rock Hill, SC.
Local emergency response needs result'ing from large population concentrations, the design of the facility and prevailing meterology make a 10 mile EPZ inadequate in the event of a radiological emergency.
The design of the facility is such that the planning bas ~is which underlies the 10 mile standard is inappropriate for applicaiton to the facility.
NUREG 0396, I
Planning Basis for the Development of State and Local Government Radiological Emergency Response Plan in Support of Light Water i
Nuclear Power Plant, (December 1978); NUREG CR 1659, supra.
i
!j h
- o N
l
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I The major metropolitan population is situated dowanind from the facility.
ER Table 2.3.0-1.
s 4
Applicants have not provided reasonable assurance that gh adequate protective measures can and will be taken by state, local and utility emergency preparedness officials and other enities and persons, such as medical facilities, fire fighting and law enforcement organizations and social service agencies, in the event of a radiological emergency as required by 10 CFR Section
~
50.47 and Appendix E, and the specific criteria as set forth in NUREG 0654, Rev. 1 The facility is located in South Carolina near the North Carolina border.
Rock Hill, South Carolina, is approximately 5.8 miles from the plant and had a 1975 population of 35,346.
Nearby Charlotte, North Carolina, had a population of 281,417 within the city and lies only 10.5 miles from the plant.
The Charlotte-Gastonia SMSA had a 1975 population of 592,706, the
~
bulk whigh lies within 20 miles of the plant, TSAR, 2.1-1, Table 2.1.3-2.
U.S.
Department of Commerce, Bureau of the Census, i
County and City Data Book 1977:
A Statistical Abstract Suoplement, (Washing ton, GPO, 1978), pp. 548, 720 and 744.
Recreational r
use of Lake Wylie, adjacent to the facilitiy and Carowinds amusement park, 8 miles from the plant, and religious gatherings at Heritage, USA, facilities'of the PTL Club, and other nearby l
activities introduce transient populations in excess of 60,000 e
i
)
1.
I l
on a peak day.
FSAR, Tables 2.1.3-17 and 2.1.3-19, p. 2.1-3.
Applicants are apparently unaware of the Heritage, USA, facilities.
Neither stare nor local emergency preparedness plans have been developed with respect to the plant to protect people living within either the plume exposure or ingestion pathway EPZs.
Although Applicants may anticipate the preparation and development of plans meeting the paper requirements of NURIG 0654, Rev. 1,"a good well wr.itten jlan :.is.an Limpor. tant step towafck achieving.a preparedness capability, but it is only that."
FEMA, Report to the President:
State Radiological Emergency Planning and Preparedness in Support of Commercial Nuclear Power Plants (June 1980), p. VI-2.
Applicants have no intention of conducting the (f) (1)',
. " full-scale exercise," called for by 10 CFR Part 50, App. E but only well-rehearsed drills involving no significant movements of population.
5 No reasonable assurance can be had that the facility can be 7b
}"
operated without endangering the health and safety of the public dhrough occurrence of a serious accident, beyond design basis.
The probabalistic risk. assessment which might serve as a basis and standard for finding a reasonable assurance of an acceptable risk to the public can not be carried out because human errors and common mode failures are not susceptible to that method of analysis and because the complexity and number of nuclear plant
i systems defies such analysis.
Such serious iss'ues have been raised and ;hown regarding the conceptual, methodolog'ical, l
l statistical, and data underpinnings of the RSS that its use in.
i j
licensing proceedings for decision-making is entirely inappro-c I
i priate.
NUREG CR 0400, the Lewis Report, Supra; Union of Concerned Scientists, "The Risks of Nuclear Power Reactors:
A Review of the NRC Reactor Safety Study WASH 1400" (NURGE 75 014), pp. 113-130.
Serious accidents with releases of radioactivity to the environ-ment inimical to the health and safety of the public are now plainly credible after Three Mile Island.
J i
6 Substandard workmanship and poor quality control strongly 3
b suggest that actual plant construction is substantially below 1
l NRC standards in many safety related areas.
Applicants have l
)
failed to provide a Quality Assurance program which meets the requirements of 10 CFR Part 50, App. 3, and no reasonable assurance exists that the plant can operate without endangering i
l the health and safety of the public.
The Commission has noted, that "the regulated industry.
. bears the primary responsibility for the proper construction'and safe operation of licensed nuclear facilities."
Federal Tort Claim of General Public Utilities Corp., et al, CLI 81-10, 13 NRC 773, 775-776 (1981).
The NRC's Systematic Assessment of Licensee Performance Review Group found
.the Catawba f acility "Below Average" among power reactor facilities" 1
9
[
. y - - --
(-
l-j-
i under contruction particularly "in the areas of quality assurance including management and training."
NUREG 0834, NRC Licensee 3
i Assessments, August 1981, p. B-1.
A number of former Duke Power i
9, Company construction workers, including a certified Quality control Inspector, have complained of systematic deficiencies in l
plant construction and company pressure to approve faulty workman-j ship.
}
l, i
7 No reasonable assurance can be had that the facility can be
(
operated without endangering the public health and safety because of Duke's consistent failure to adhere to required Commission operating and administrative procedures provided for in Commission rules and regulations.
"The Nuclear Regulatory Commission has the statutory responsibility for prescribing licensing standards to prJtect public health and safety and for inspecting the industry's activities against these standards.
The Commission does not
~
thereby certify to the industry that the industry's designs and i
procedures are adequate to protect its equipment or operations.."
I Federal Tort Claim of General Public Utilities, Coro., et al, CLI-j i
f 81-10, 13 NRC 773, 775-776 (1981).
At both Ocon'ee and Catawba facilities of Duke Power Company the Systematic Assessment of Li'censee Performance Review Group found "weaknessess in personnel l
adherance to operating and a'dministrative procedures" and "failu:re' to follow procedures."
NUREG 0834, Licensee Assessments, August 1981, O
j 1,
pp. A-3, B-1.
As icng ago as 1977' Duke, Licensee for the Oconee facility, was assessed civil penalties of $21,500 where:
"the history of repetitive and chronic non-compliance, when considered in conjunction with failure to institute effective corrective action and management controls, demonstrates that 1
management is apparantly not conducting licensed activities with adequate concern for the health, safety or interest of its employees or the general public."
Ernst Volgonnau, Director, Office of Inspection and Enforcement, USNRC, to C.arl Horn, Jr.
President, Duke Power _ Company, March 29, 1977, Docket nos. 50-269, 50-270, 50-287.
8 No reasonable assurance can be had that the f acility can (O.
be operated without endangering the public health and safety because the Applicants' reactor operators and shift supervisors lack sufficient hands-on operating experience with large pressurized I
water reactors.
The resumes of Catawba Plant Supervisors show
' that only a very few of these individuals who will have primarh management responsibility for safe operation of the plant, FSAR, Table 1.9-1, p.2, have experience at large PWR's like Catawba.
NUREG 0737, Clarification of TMI Action Plan Requirements, I.C.3.
Resumes of Senior Reactor Operators.and Reactor: Operators show similar lack of experience.
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t 9
Applicants have failed to demonstrate that during the time
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period following a postulated LOCA but prior to effective oper-b h
tion of the combustible gas control system, either (i) an.uncon-kb trollable hydrogen-oxygen recombination would not take place in the containment, or (ii) the plant could withstand the consequences t
of that hydrogen-oxygen recombination without loss of safety I
i function.
The containment of Catawba is a thin-walled, dry ice condenser containment designed to withstand internal pressures of only 15 psi.
(FSAR, 6.2-1.)
Hydrogen release consequences of much higher pressure have been experienced at TMI and are likely to occur at '
Catawba in the event of a range and variety of LOCAs.
Failures in Quality Assurance undermine confidence in the quality of construction of the containment and ice condenser systems so that no " built in" conservatisms beyond the design basis should be relied upon to provide a margin of safe y.
10 The economic costs of a severe accident with release of....
(f) radiation to the environment (a so-called Class 9 accident) were not considered in the CP review for Catawba'.
Such an accident could have enormous cost consequences especially in the event of an atmospheric release with the winds blowing in the direction of the major population of Charlotte, NC, or Rock
- Hill, SC.
l l
/
.Z__.
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e 11 The costs of construction of Catawba have risen from 'an estimated $699.4 million in 1972 (CP Application, July 1972, p.8) h hb to an estimated actual cost of $2,287.0 million (OL Application, Ogt June 1981, p.13), including original fuel cost.
A tripling.of actual over estimated costs can only adversely affect the putative Cost-Benefit balance struck earlier.
[312 The need for funds for a capital-intensive form of energy production has placed added burdens on a tight capital market and increased interest rates in the economy as a whol'e.
13 Investment in capital intensive, rather than labor inter.sive, b
gfb approaches to dealing with energy needs reduced monies available in the market to create jobs for residents of the Catawba ar.ea.
The 845 jobs projected for Catawba will have been at a capital cost of some $2.7 million per job.
Investments in conservation would have created more jobs.
14 The Applicant's Environmental Report should provide a full
('E(? description and detailed analysis of the environmental effects of f
the transportation of spent fuel shipments to the Catawba Plant l
from other Duke Power Company f acilities and of the contribution i
of such effects to the environmental costs of licensing Catawba, the values determined for such analysis for the environmental l
e W
's
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impact under normal conditions of transport and the environmental risk from accidents in transport as required by 10 CFR 51.20 (g) (1)
(a) (ii).
The values set forth in Summary Table S-4 do not apply here because those values apply to the shipment of a reference quantity of spent.fucl from a reactor to a fuel reprocessing plant or of solid radioactive wastes to a waste buri'al ground as set forth in 10 CFR 51.20 (g) (1) (a) (i) and not those likely to an Away From Reactor (AFR) storage facility.
Applicants seek such additional source, special nuclear, and by-product material licenses as may be necessary to allow the storage of spent fuel from other Duke nuclear facilities.
(OL
, Application, pp. 11-12).
15 Failure to estimate the environmental costs of ope, ration of hb Catawba as an Away From Reactor (AFR) storage facility for spent D
f fuel from other Duke nuclear facilities and transportation of that irradiated fuel to Catawba compromises the validity of the favorable Cost-Benefit balance struck at the construction permit phase of this hearin.
Since the CP stage hearing, Applicant Duke _P.ower has considerable expanded the Catawba spent fuel pool capacity and provided for denser storage of irradiated fuel.
FSAR Table 1.2.2-1.
Applicants intend to use Catawba as an AFR for irradiated i
fuel from the McGuire and oconee nuclear facilities of Duke Power Company.
(FSAR 9.1.2.4, OL Application, pp. 11' 12. )
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i 16 Applicants have. not demonstrated their ability safely to g(
transport and store irradiated fuel assemblies from other Duke nuclear f acilties so as to provide reaso'nable assurance that those activities did not endanger the health and safety of the public.
l Applicants have made no provisions for the safe storage 17 gb of irradiated fuel at Catawba after expiration of the license i
for the faciltiy and have not demonstrated their ability to safely accomplish that storage for an indefinite term.
To date, no available temporary or permanent off-site spent fuel storage or reprocessing facility is available.
18 The Applicants have failed to demonstrate that the diesel
'D generators which are critical to the safe shutdown and control of the reactor in the event of loss of off-site power are designed, constructed and operated at standards sufficiently high that they may be relied upon to reasonably assure that the h'ealth and safety of the public will not be endangered.
The FSAR does not give adequate information or assurance that all regulatory requirements have been or will be met prior to operation.
See FSAR 8.3.
)
4 Petitioner Palmetto Alliance is informed that Applicant Duke Power Company installed used generators in its McGuire Nuclear Station.
19 The Catawba Emergency Core Cooling System has not been b
demonstrated to meet the requirements of 10 CFR Part 50, Appendix K and 10 CFR 50.46.
Models used to predict ECCS performance have not been proven accurate.
The American Physical Society review of the Reactor Safety Study (WASH 1400) in Review of Modern Physics (Summer Supplement, 1975) noted the poor representation by two dimensional models of three dimensional interactions of steam with ECCS water, compounded by the vast uncertainties in steam binding.
The loosening and loss of neutron shield bolting experienced at other reactors could result in a LOCA and failure of effective cooling by the ECCS through blockage of the coolant system flow path if the nontron shield were dropped from its support.
RESAR, Figure 4.2-7.
20 The license should not be granted until Applicants have' 2
demonstrated that radiation exposure levels will be maintained as-low-as-reasonably achievable as required in 10 CFR 20.1.
l The FSAR does not adequately consider occupational radiation e
- )
I exposures to be expected from either the normal operation of l
Catawba or that which may occur during an abnormal occurence, servere accident, or maintenance once thought unusual but now
)
i understood to be reasonably expectable.
Catawba utilizes Westinghouse steam generators which have J
shown a generic tendency to denting, cracking, leaking and rupturing.
l Extensive repairs at a number of plants have been required as i
well as complete replacement of steam generators at Surry Power _-
Station 1 and at Turkey Point Plant, Units 3 and 4.
Experience 1
and estimates of steam generator replacement occu'pational l
exposures have ranged fro 5:173D man-rems / units to 5,84 0 ?
I man-rem / unit (NUREG/CR 0199, NUREG 0692, p. 4-1, NUREG 0756, 7
pp. 2-6,7).
Steam generator repairs and/or replacement at t
{
Westinghouse reactors have become so com. Ton that they must be assumed as normal maintenance.
Likewise premature embrittlement of reactor vessels and loosening and loss of reactor neutron shield bolting will result f
in increased occupational exposures.
21 Applicants have failed.,to develop new procedures and training b
guidelines for controlling or mitigating small break LOCAs, l \\
incidents of inadequate core cooling, and certain anticipated transients consistent with' and as' required b'y EURIG 0737, I.C.1.
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4 22 The Catawba control room fails to meet regulatory requirements in NUREG 0660, NUREG 0694, and NUREG 0737 in that the control i
g room lacks sufficient instrumentation for detecting inadequate l
f core cooling in case of abnormal events, Applicants have not demonstrated their ability to comply with current NRC requirements for overall control room design standards.
The Catawba control room design and instrumentation have not been subjected to a comparative evaluation of the interaction of human factors and J
ef ficiency of operation, and the FSAR fails to document how the plant can or will be modified to meet the new criteria imposed after TMI.
23 Catawba should not be licensed to operate until the b
Applicants have developed and demonstrated an adequate security g@
plan which complies with 10 CFR 73.55.
The FSAR does not give adequate assurance that all regulatory requirements have been or
~
will be met prior to operation.
See FSAR, p.
13-6.1, Regulatory Guide 1.17, Rev. 1.
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i 24 The sale of major portions of Catawba to consortiums of ph municipal power authorities and rural electrical cooperatives places an unknown and potentially impossible burden on municipalities l
and other entities which lack the resources and ability to raise the significant funds which will be required to safely operate,
=
~17-maintain, and decommission the plant in conformity with NRC rules and regulations.
As the experience of the Washington Public Power Supply System has shown, miniscule to modest size municipalities and rural electrical cooperatives cannot be relied upon as unlimited revenue resources for construction and operation of nuclear facilities.
An accident with the clean-up and liability costs of a magnitude equal to or greater than those experienced at Three Mile Island would cause many of these municipalities to default.
Moreover, local voters may at any time refuse authorization to their elected representatives to expend funds on Catawba.
25 Applicants have made no plans for ensuring that funds will k
be available to safely decommission Catawba in conformance with NRC rules and regulations.
Duke Power Company utilizes an unfunded reserve for
' depreciation expense.
Since Duke claims to have failed to match earnings to inflation, an unfunded reserve, which constitutes an investment in Duke plant, cknnot be viewed as the safest investment which could be made to ensure the presence of adequate funds when needed.
(William H. Grigg, Testimony for Duke Power Company, l
SC Public -Scrvice Commission, D6cket No. 8 0-T7B-E, p. 14).
l
[
Further, a planned unfunded reserve calculated upon present value i
l l
. a q- _.- -.
j.
. assumptions will not match future cash requirements.
Attempts to collect decommissioning funds from a myriad municipalities and electrical cooperatives af ter Catawba has ceased generating revenues will prove fruitless in many cases.
Early decommissioning resulting from an accident such as at Three Mile Island or Fermi I, premature embrittlement of the reactor vessel, or unsupportable costs of steam generator replacement would threaten to bankrupt each and every participant among the several Applicants.
26 Because of continuing cut-backs in funding for the South DC d
arolina Department of Health and Environmental Control, that body cannot fulfill its responsibilities of monitoring the environmental effects of operation of Catawba to provide reasoncble assurance that the health and safety of the public is not being endangered, or adequately perform its responsibilities'in the event of a radiological emergency.
2,7 The Applicants should be required to place real time monitors capable of reading ~ gamma radiation levels around the S
site in order to provide emergency operations personnel with the information required to make decisions necessary to reasonably assure the health and safety of the public under crmMtions of radiological release to the environment.
.... ~
Thermoluminescent dosimeters are only accurate within about
+30% and only provide a post hoc assessment of conditions.
28 The applicants have failed to demonstrate that the risk from an ATWS event is sufficiently reduced by interim measures Sk prior to resolution of generic issues and Commission direction i
ks on corrective actions provides reasonable assurance that the 4
Catawba plant can be operated prior to that resolution without
~
endangering the health and safety of the public.
NUREG 0460 " Anticipated Transients WithouttScram-for Light Water Reactors"'forthl.the Staff position that "the reliability of current scram systems cannot be shown to be adequate to meet the safety objective considering the rate at which these systems are challenged by anticipated transients" (p.39).
The Staff i
position articulated in 1973, (NUREG 1270) was that the likelihood of an ATWS event was acceptably small given existing in 1973.
Since
~
that time, the number of reactors has increased dramatically.
It is simply irrational and inconsistent to argue, at once, that there is a problem of sufficiently high risk that changes ought to be made and that those changes can be made down the road somewhere.
Probabalistic arguments that an event is likely to occur only once in x many reactor years do not make it any less likely that at y plant that event vill occur this year.
l
J
+.
6.
29 The potential impacts of systems interactions and particularly the safety implications of control systems and giant dynamics h) have not been sufficiently accounted for by Applicants in order::
that the safety and health of the general public can be reasonably assured during the operation of the Catawba plant.
Demetrios L. Basdekis of the NRC Staff has, in a number e
of memoranda and appearances, addressed the inadequacy of current understanding of the safety implications of control systems and plant dynamics.
Those concerns should be addressed with specific reference to this plant.
In the ACRS study of LERs (NUREG 0572, " Review of Licensee Event Reports"), the ACRS found a number of systems interactions which only were revealed by their actually occuring.
30 The Board should dismiss Applicant's Application for an p(?
Operating License.
The Catawba plant is not needed nok.
Both h(h Applicant's and Staff's need forecasts made at the CP stage have proved grossly defective as to level of need and rate of growth.
CESG's forecast, in contrast, has proved accurate.
The earliest possible date of justifiable operation of' Catawba is a decade hence, unless, as appears likely, growth in need decreases further.
A realistic, favorable, cost / benefit consideration is rescinding the CP and mothballing the plant until and unless the cost / benefit consideration for continuing t
\\
j construction becomes favorable.
l 31 The license should not issue until and unless the hydrogeh hb release consequences from that range and variety of LOCA's i
which the Applicant is required by the NRC to consider have been dealt with so as to make impossible damage to public health and safety.
The igniter system cannot perform this function.
The license should not issue because the risk evaluation
,pc' 32 kh made by the Staff is inadequate.
The totality of risks, including
~
those demonstrated at TMI-2, in relation to the possible consequences for' this specific site, have not been considered.
P The operating risks, p1'us those associated with decommissioning, the transport, and both interim and long term. storage of radioactive substances resulting from generation, must be taken
~
into consideration in striking a cost / benefit balance vis-a-vis alternatives.
These risks are significant and greater by far than those assumed at the CP stage.
It is not within the capability of Applicant nor NRC to prove the absence of
~
substantial risks to public health and saf ety over the period of time which radioactive materials formed by generation remain hazardous.
gfh 33 The license should not issue because the cost / benefit 6
gBP
g.
?
. l t
statement has become grossly defective.
Slow construction, due primarily to Applicant's erroneously high forecast of growth in electrical demand, will result in Catawba power being more expensive than a number of alternatives, including conservation and renewable energy sources.
This has been demonstrated by
~1 Applicant's 10% increase in rate with declaring McGuire, a plant similarly affected by slow construction, commercial.
566 The license should not issue because it will, contrary to 34 g
the intent of cost / benefit consideration, further burden the hh D
consumer, not only with construction costs and the interest en construction borrowing, but with an entirely undeserved earning t
en an unneeded facility.
The CP stage cost / benefit statement is grossly defective.
4 tLg 35 If a license issues, it should require that emergency b
planning for the EPZ include the city of Rock Hill.
Because the l
plant is a low pressure, ice condenser containment type, and because the consequences of severe accidents are estimated to extend to at least 25 miles, a radius of 30 miles should be the basis for emergency planning.
This would include the city of Charlotte.
8 3,6 The EIS should explicitly consider the consequences for the
)
l
N
_23 specific site of the entire spectrum of serious release accidents, including PWR-1 to PWR-9 as formulated in the Reactor Safety Study.
This consideration should include the recognition that"
[N,
_ local officials and resources are not qualified to assure protection of the public health and sa; sty in the event of a serious accident.
37 If a license issues, an adequate crisis relocation plan should b
yb be a condition for issuance.
The nature of particulate releases
~
in sericus accidents, such as PWR-1, is such that relocation of the af fected population is required.
Present plans are deficient in that no consideration is given crisis relocation.
38 The operating license should not issue because part of 'the construction was not covered in the CP and the CP was amended b
without due process.
The fuel pool was greatly expanded by an
@Fb v
amendment.
Enlargement of the fuel pool significantly increases the sources term for fuel pool accidents, including boiling dry followed by fuel melt.
39 A license should not issue because, since the CP stage, in gh 2 response to the mandates of North Carolina legislation, the Applicant has embarked on a variety of programs designed to decrease load growth such as load management, special rates for I
(
l l
... ~....- -....
conservers, and a program to assist hom6 owners.in reducing thermal loss.
The cost / benefit statement of the CP stage was struck absent these considerations.
e 40 The license should not issue because irregularities in fh the welding practices on safety related systems eddanger' the public health and safety.
a _
41 The license should not issue because Catawba was designed (b
and is being constructed withou't appropriate consideration of electromagnetic pulse.
EMP will knock out most of the power grids on which Applicant could rely for backup power, knock out most if not all electronic and electric communications systems on which Applicant routinely relies, knock out all control systems relying on solid state components, knock out all computers including the off site computer used for moni'toring the ECCS thereby making possible a variety of reactor accidents not forseen including the boiloff of water in the fuel pool.
1 l
42 The license should not issue because the design of'the
'h control room preceded knowledge of the essential role of human
(
factors considerations in design, a factor in the TMI-2 accident and in other operating problems having in common avoidable operator error.
b e
M
(._,.-...
43 The license should not issue because no consideration has been given to the effects of Corbicula, known to infest the
'd?
hN Catawba River and Lake Wylie, on the performance of the cooling tower system.
44 The license should not issue because reactor degradation in the form of a much more rapid increase in reference temperature A(i O V
than had been anticipated has occurred at a number of PWR's including Applicant's Oconee unit 1..
Until and unless the NRC
~
and the industry can avoid reactor embrittlement, Catawba should not be permitted to operate. -
45 The license should not issue until and unless the loosening gh of reactor neutron shield bolting and'the loss of such bolts' in understood and prevented.
Dropping of the neutron shield from its support, RESAR Fig. 4.2-7, would result in blockage of the coolant system flow path and, despite the ECCS, lead t a major LOCA.
46 The' license should be withheld as no provision has been made for the release of substantial amounts of radioactivity to.
hb7 Lake Wylie, the source of potable water for many down stream communities.
Such a loss can occur in an accident such as happened at Oconee, in which the quantity of radioactive water resulting
o '.
,... 4 4
from washing down a contaminated area exceeded the holding capacity, or from any one of a variety of as yet unencountered operational errors.
/
1 47 The license should not issue because Applicant's Environ = ental Report is deficient in that it does not ' consider the health effects of tritium, considers only airborne volatiles,as a source of dosage, ignoring water pathways, and does not consider the consequences of the release of radioactive particulates.
48 The license should not issue because the dilution of owner-gk, ship was not considered at the CP stage and presents a series of problems in connection with responsibility and liability.
A 75% interest in Catawba has already been sold.
It is Applicant's intention to dispose of the remainder.
As the terms of purchase are unfavorable to the buyers unless Applicant's unreal'istic forecast of sales eventuates, the owners of the plan'. pill be unable to meet the burdens of ownership, including a proper Assumption of liability.
4 a4
/
27-WHEREFORE:
having supplemented its Petition to Intervene with this list of the contentions which it seeks to have litigated in this proceeding, and the bases therefor, Petitioner Palmetto Alliance requests that its Petition be granted, that it be proyided an opportunity to be heard in support of its interest in this matter, and that the Application of Duke Power Company, et al.,
for. licenses with respect to the Catawba Nuclear Station, Units 1 and 2 be denied, or so conditioned as to protect the health, safety and economic interest of Palmetto Alliance and the public.
r S
December 9, 1981 Robert Guild 314 Pall Mall Columbia, South Carolina 29201 (803)252-0929 Attorney for Palmetto Alliance e
e
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