ML20040C719
| ML20040C719 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/25/1982 |
| From: | Bier J, Christamaria, John S, Mills J, Oneill J BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | |
| References | |
| ISSUANCES-OLA, NUDOCS 8201290179 | |
| Download: ML20040C719 (11) | |
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Jaruary 25, 1982 U
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2.2/pg P2:Sh UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CONSUMERS POWER COM PANY
) Docket No. 50-155-OLA 2
(Big Rock Point Nuclear Plant)
) (Spent Fuel Pool Expansion)
TESTIMONY OF CHRISTA-MARIA, JOANNE BIER, JIM MILLS, SHIRLEY JOHN, AND JOHN O'NEILL Intervenors Christa-Maria, Joanne Bier and Jim Mills hereby submit testimony of the above named persons with respect to Christa-Maria Contention No. 9.
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4 Herbert Semm'el Of RECE1VED Attorney for Christa-Maria f3 Joanne Bier, Jim Mills 2
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e Contention Christa-Maria et 1_
The expansion of the spent fuel pool requires a change in the emergency plan to take into account the significant increase in radioactive spent fuel that will be stored at the site.
Arguments for the Board required nexus:
A.
Any method that requires Big Rock to obtain their capability to store more fuel under the same con-taig.ent as is already present does change the fuelpnventory.
B.
HigheramountsoffueNinventoryaswellashigher amounts of radioactivity due to their spent fuel status.
Big Rock re ies for Emergency planning on the C.
Nureg-0396}guidelinesthatalreadypermitsre-ducing the size of the standard Emergency Planning Zone from 10 miles to 5 miles.
e D.
Breach of Containment would allow a higher fuelin-ventory to escape and therefore endanger the public in ways Emergency planning currently is not ade-quate to handle.
PRA analysis as well as MCA evaluations that stda that the effects of a postulated accident are in-significant are already influencing standard Nureg-0654 required planning.2)
The laxaty and timegap by which the NRC is able to even enforce current emergenc $1anning leaves serious doubt that in the reality of an accident i
condition the public is protected as lead to believe.
Big Rock's fuelinventory differs to the extent that some fuel is MOX under an Exxon fuelresearchprogram the higher plutoniumcontents do not concurr with the "MWt equals fuelinventory contents" assumption.
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- 1. Fed. Reg. Vol 45, No.162, Aug. 19, 1980 l
- 2. Letter NRC to CP(Mr. Hoffman Nov.20.,81 Is 6
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A.
Sheer logic reasons that anything that is considered dangerous does not get less dangerous, stays even or evaporates by an increase of the same elements.
An increase from 193 dangerous fuelelements to h41 lis substantial, the,.. element of dangerous quantity al imost doubled.
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t B. Spent Fuel has a higher amount of dangerous radioactive elements.Although some will be reduced by decay enough of it is present by almost doubling the amount capable for the pool to handle.
A smaller increase of 'spedtofuel'infthe pool would reduce the amount of radionuclides that could escape or could cause concern under accidentconditions.
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POINT C.
Big Rock relies for emergency planning on the Nureg -
0396' guidelines that already permit reducing the size of th'e standard Emergency Planning Zone from 10 miles to 5 miles (Federal Register Vol 45 no 162 Aug. 19,1980 p. 5849)
The NRC has already recognized the uniqueness of the Big Rock Point facility by reducing the size of the EmergencyPlanning Zones (EPZ) in a letter dated June 13, 1980.
The inhalation pathway was reduced from 10 to 5 miles and the ingestion pathway was reduced from 50 to 30 miles.
The letter states that facilities with less than 250 MWt have a lower potential fo r hazard due to lower readionuclide inventory and longer time to release significant amounts of activity.
Letter dated Nov. 20, 1981 to David Hoffman - Nuclear licensing administra-
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tor from Dennis M. Crutchfield Chief of Opera-ting Reactors Branch #5.
Div. of Licencing.
The assumption that plants with less than 250 MWt have a lower
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potential for hazard due to lower radionuclide inventory and longer times to release significant amounts of activity applies maybe to a regular fuel inventory but should be specifically differ to Big Rock's fuel inventory.
Longterm operationhas produced a significant higher amount of decayed dangerous fuel than a comparable new facility of the
-same capacity to produce MWt.
The fuel'at Big Rocks also dif fers in composition to other facilities by being used for research purposes by Exxon.
The plutonium contents in over 20 assemblies is much higher than fuel used by other facilities.
POINT D.
Breach of Containment would allow a higher fuel inventory to escape and therefore endanger the public in ways Emergency Planning is not currently adequate to handle.
Breach of containment is a possibility that can not be ruled out for ever just because all rules regulation and safe-ty measures are designed to prevent this occurance.
Murphy's law does exist so do natural occurrances as well as the real
3 possibility at Big Rock due to an impact of an aircraft.
None of the above can be fully regulated by the regulatory process.
At least not to the 100% effect that is deemed necessary to protect the public.
Nuclear Regulator Commission Chairman Nunzio Paladino in a speech to the Atomic Industrial Forum in San Francisco in December 1981 stated " Quality cannot be inspected into a plant it must be built into the plant."
The current emergency planning for the area around the Big Rock Point Power Plant does not take into account the change in the type of fuel the plant was designed for and the recent re-loa'ds whi~ch use recycled plutonuim fuel.
The increase is 3.3 times greater than the Big Rock Core without recycle plutonum.
"The increased quantity of plutonuum in the Big Rock Point core introduces the possibility that core nuetronics are afflicted unfavorably or that the increased toxicity of plutonuim results in an unacceptable increase in radiation doses to the public during normal or post-accident conditions,"
United States Atomic Energy Commission Docket No. 50-155 Dec. 6, 1972.
In light of the increase in hazard to the public at the Big Rock Point plant it seems imp. udent to reduce the Emergenc-l Planing Zone under the assumption that plants with less than 250 MWt have a lower potential for hazard.
Breach of containment would release higher amounts of radiation and at a faster rate than is currently being planned for.
The NRC in Aug. o f 1981 extended by seven months the deadline calling for accident warning systems to be in place.
This merely extends the risk to the public at large.
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In addition, when a concern was raised to Brian Grimes, director of the division of Emergency Preparedness, that the Public Information Program that children and pregnant women are under higher risk and require special attention during a nuclear emergency he replied:
We agree with your concern.
The Public Information pamphlet is generally weak in providing useful.in-formation about radiation hazards.
We will address l
this as part of our review.
There is still nothing addressing this concern in any revision of the pamphlet.
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y POINT E.
PRA analysis as well as MCA evaluations that state that the effects of a postulated accident are unsignificant are already influencing standard Nureg - 0554 required planning. 2.
D M " p. Tne MCA evaluation that is alco usbd in Op's PRA states that a con porcent coro melt is insi:mificant and that a 100 percent corenelt is insignificant, the staff in their EIA/SER and staff ancwer to summary dispositions on concentions deem a boiling of the pool insignificant as well as the increase of radionuclides due to a,fuelpool expansion in-significant.......
If all'. these insignificants do not add and breach" of containment that could maybe change the calculated ha,ards are as remote as a meteor dropping fromthe sky.......
What is the need for an NRC, their inspectors Federal Rules and Regulations, taxpayers money to support a tremendous machinery of mail, cop'ying, technicians etc.?
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g b p D.Because of TMI rules and regulations were passed to' insure better emergenc$ planning for utilities and tkLuAMr.,w com. unities surrounding their nuclear facilities.
Mainly the NUREG o654 are used and have been ordered to implement.To the most they are well designed to protect the public.
However even on a very simple matter required as a pamphlet to inform the public of information needdd to educate themselves and how tp protect themselvss, insufficiency to say the least is present.
Because these pamphlets are allowed to be distrib ted before the appropiate NRC office has edited ob approved it the contents can be read more as propaganda for the nuclear industry than information really_ serving the public as the intend of the NUREG's 0654 specify.
Not to mention the politic's of the county that may or may l
not want to have pamphlets distributed, or sirens, or i
other Fed. mandated emergency items that Big Rock has to comply with in order to keep it's license.
The above mentioned pamphlet has been as of this date not distributed to the public as fed. required, just laid out at several keyplaces for people to take.
I Technical items, such as monitoring equipments etc, sufficient personal to insure proper control in case of an incident has been continually deferred by the utility or is beeing reduced.(Big Rock's TMI related requirements)
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The evacuation time for the 0-5 mile area is substantially higher for the area surrounding Big Rock Point than with other power plants.
The results for the Palisades Plant show that evacuation clear time in the 0-10 mile areas approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for both summer and winter conditions.
At our Big Rock Point Plant the evacuation clear time for the 0-5 mile area is approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in the summer and approxi-mately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in the winter.
Letter from David Hoffman of CPC to Dennis Crutchfield, Chief of operating reactors Branch #5 date l
l July 23, 1980.
This time delay needs to be taken into account for the emergency planning.
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'The Stato as :well' as the County emergency plan operates on the assumption that Big Rock has met all Fed. required 7
rules perataining to emergencyplanning, yet a whole mess of required technical items are beeing deferred and or cahanged.
Having the State or County assume that Big Rock can totally meet all Fed. requirements when they are actually in a state of flux could hinder drastically the intended plan of action by which to proceed under emergency conditions.Noither the State nor County officials are familiar with Big Rock's current status of compliance to rules and regulations, by law they are not recuired to be. Not understanding for instance what a breachr,of containment) could mean wrong assumptions could easily be taken and wrong guidance given to the public.
The grossneglect by Consumers Power to truly inform the public of the dangers of radiation, meaning a breakdown of gases and nuclear isotopes that explain the dangers and the difference in matters like inhalation, digostion or external exposure give the general population very little chance to use the right instincts or protective measures.
On 6 5.81 I was prosent to discuss the revision for a new energencypamphlet.At the meeting Consumer Power people were present (Axtell, Jury,Loomis, county omergency officials Jim Mills, Myself) disturbing was the fact the the utility over the objections of county officials refused to be part of nor be part of any planning for persons that have no
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transportaion or are hindered to obtain it.
The Sheriff keeps a list of invalids etc.fdividual but it is not kept current by any other means than an i
D. cont.
registoring with the Sheriff and to be on his " list" should an accident occur.
The County Emergoneydirector is greatly hindered by financos and resources to do the job he may intend to do, for the town is not willing to approp. moneys for his office, feeling it is not neccessary or what else...
The list of personell the emergencydirector has to enforce his duties in caso of accident is not fully backed-up and most of those people do not even have a mandatory education of nuclear radionuclidos and their potential of harm to the populus or biological environment.
'dhon TMI happened the real people experienced emotional trauma had problems with transportaion, obtaining finances to execute i
their exit and are living with the fear of the unknown what the accidental releases may have done to their ability to j
secure healthy offsprings as well as for their own health.
j That was a real event for real people.
I The NRC and utilities were supposed to learn from that and give f
us some kind of assurance to deal with a future incident in a way that protected the public better.
4 All of this may exist on paper but not in reality for the people living around Big Rock.
Bridges do not always close, bank lomployees like to leave as well i
as gas station attendants, do sch'oolbusdrivers have to take l
large exposuredoses to " rescue" the' children, will parents obey?-
All planning is structured on the assumptions that people will obey like sheep for something they do not even understand or can I
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- kaiw inatinnt, tn cuide them.
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CERTIFICATE OF SERVICE
'82 JN126 P?
I certify that copies of the foregoing testimony of r
Christa-Maria, Joanne Bier, Jim Mills, Shirley Jol$n, 'and John O'Neill were served on the attached list on the 26 day of January, 1982 by delivering copies to the office listed thereon or by U.S. mail, first class postage prepaid,.
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4 Herbert Semme.K