ML20040C802
| ML20040C802 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/26/1982 |
| From: | Semmel H ANTIOCH SCHOOL OF LAW, WASHINGTON, DC, BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | |
| References | |
| ISSUANCES-OLA, NUDOCS 8201290253 | |
| Download: ML20040C802 (4) | |
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UNITED STATES OF AMERICA
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$thgWv BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of
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CONSUMERS POWER COMPANY
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Docket No. 50-155-OLA
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(Big Rock Point' Nuclear Plant)
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(Spent Fuel Pool Expansion
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INTERVENORS' SUBMISSION OF DEPOSITION OF MESSRS. 1 ' ELL D
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SINDERMAN AND BLANCHARD IN OPPOSITION TO MOTION FO 3
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SUMMARY
DISPOSITION AND AS EVIDENCE AT HEARING.
tang Intervenors hereby submit the depositions and all exh
nn thereto of Charles Axtell, plant health physicist at Big Rock Point Plant; Roger Sinderman, Director of Radiological Services at gene-ral offices of Consumer Power Company in Jackson Michigan; David Blanchard, technical engineer at Big Rock Point Plant, taken on January 12, 1982-in Washington, D.C.
The attention of the Board is specifically directed to the foll-l-
owing:
John O'Neil Contention IIB; p.70 (Mr. Sinderman) "The storage of leaking fuel assemblies does for a short period of time increase the amounts of radiation in the pool water -- amounts of radioactive material in the pool water, and does increase slightly the amoant of radioactive materials released from the facility."
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116 (Blanchard) "[T]here are no formal procedures for maintenance of equipment associated with the spent fuel pool or, in fact, the plant in general."
109 Instruments designed to detect radiation are twenty (20) years t-old, as well as the back up instruments.
p.117 In an instance where workmen had carried off contaminated J
domineralized water for home use there is no indication that the plant checked to see the extent of exposure to the workers or their families.
pp. 156-157 Big Rock Point has higher dose rates than other power plants.
Newer plants have a radwaste domineralizer set aside to process only spent fuel pool water.
Big Rock's demineralizer process not only the spent fuel pool but almost all water entering radwaste area.
In addition to support this contention, Intervenors submit incident reports received at the deposition, numbering in the hundreds.
John O'Neil Contention IIF; p.190 discussion of samples taken from aquatic community and milk.
The methods used.
See the affidavit of Berndt Franke submitted January 25.
John O'Neil Contention IIE-3; p.84 Mr. Blanchard describes compacting of spent ftiel as usually containing nuetron absorbing boron between fuel bundles to keep reactivity low in the racks.
He further states that the proposed
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p.205 (Mr. Sinderman)... [I]f one adds more fuel to the pool, one could expect some increase in alpha-emitting materials in the pool.
p.172 Past Problems with the containment valves are outlined in the Prohability Risk Assessment Appendix 4.
l John O'Neil II G-b l
(. r. Sinderman) "We do have, of course, an accounting system p.73 M
which will tell us what our total effluents are from the plant, either released to the atmosphere or to the lake.
We cannot, however, specify which portion of them would come from the spent fuel pool or any other specific source in the plant."
Christa-Marie Contention 8 and John O'Neil Contention IIE-2:
p.139 (Mr. Axtell) "Its a well known fact that this plant is not equipped to handle an accident where large quantities of water are generated."
John O'Neil Contention IID; p.56 "Q. What information do you have concerning the number of flights
-- lets start with that go directly over the plant?
A.
We keep no record of that."
John O'Neil Contention 7; p.14 There have been two releases from emergency condensor.
p.26 Fire pump is electric not diosal p.32 (Mr. Blanchard)
"No, there are no written procedures of any kind that I was able to locate dealing specifically with anything associated with the pool."
p.36 There are no written standing orders on routine maintenance procedures (Blanchard) "Nothing specific associated with.the spent fuel pool."
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. compacting at Big Rock Point would not have these boron sheets.-
dkJ IIerbert Semmel Attorney for Intervonors Christa-Maria Milen and Bier Antioch School of Law 2633 16th Street, N.W.
Washington, D.C.
20009 (202) 265-9500 CERTIFICATE OF SERVICE I certify that copies of the foregoing submission of Depositions were served on the attached list on the 9,[n 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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1 Herbert Semmel /
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'82 JM 26 P2:53 ynuGC. ;<no a at!p.1 dtlA!ICh
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