ML20041C355
| ML20041C355 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/17/1982 |
| From: | Dan Collins CITIZENS FOR SAFE ENERGY, QUAD-CITY ALLIANCE FOR SAFE ENERGY |
| To: | COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20041C353 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8203010206 | |
| Download: ML20041C355 (6) | |
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jM CitizensForSafeEnergy I
P.O. BOX 23 HILLSDALE, IL 61257
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I CoChairpersons Artyn Dell-Erie,IL I
Bob Miller - Clinto% IA i
Secretary Marliyn Boo -;lilladale,lL l (
Treasurer Phytils Hohenboken - Hillsdale,lL o
b b Board Members Dent.is Heller - Prophetstown,lL f
I h Jim Jacobs - Geneseo,lL j
Lantz Ropp -Geneseo,IL i
I Jack Smith - Rock Island,IL d
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Karen Vroman - Erie,IL
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._.g Feb. 17, 1982
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In the Matter of Docket Nos. 50-254-SP Commonwealth Edison Company 50-265-SP
( Quad Cities Station,
( Spent Fuel Modification )
Units 1 and 2 )
Citizens for Safe Energy's and the Quad Cities Alliance for Safe Energy and Survival's partial reply to Commonwealth Edison Company's and Iowa-Illinois Gas and Electric Company's First Set of Interrogatories and Request for Production of Documents.
We as Intervenors in this proceeding, after careful consideration, request permission to withdraw Contested Contentions 1-4.
Attached are statements of explanation pertaining to each of said Contentions.
As of this date we have not been able to secure legal counsel.
We ask that all parties involved please try to understand the difficulties that this problem presents to our groups in this proceeding.
We, as Intervenors, will make every effort to comply with your request to answer said Interrogatories as rapidly as possible.
8203010206 820223 i PDR ADOCK 05000254 C
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i le Contention 1:
The affidavits provided by Richard J. Goddard ( Counsel for NRC Staff ) prior to the Dec. 8,1981 settlement conference, as well as the settlement conference itself, were helpful in answering most of our questions pertaining to this contention.
This contention is still a matter of concern to us, however, for lack of ability to research this contention further we request permission to withdraw Contested Contention 1.
Contention 2:
The basis for this contention will continue to be a matter of concern in that Area Radiation Monitoring Systems should be adequate and reliable.
With that in mind we feel that the immediate concern, being that of the re-racking application, has been adequately answered for us. Therefore, we ask permission to withdraw Contention 2.
Contention 3:
- a. We feel that the performance and durability of Borafler as a neutron absorbing material has been proven for the remainder of the operating life of the Quad Cities Station.
The long term durability of Boraflex is still a matter of concern to our groups. Intervenors understand that Iong Term pertains to time periods beyond the operating life of the plant and would therefore be inadmissable in this proceeding.
- b. It is the opinion of the Intervenors that the part of this contention pertaining to the corrosion rate of the stainless steel in the proposed racks has been satisfactorily answered by the affidavits submitted to us during the D3c. 8, 1981 settlement conference.
Because of the reasons stated above we request permission to withdraw contention 3
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t-Contention 4:
i Intervenors believe that all radioactive waste treatment and cooling systems must be adequate and reliable.
Intervenors agree that, according to the current design standards, the systems in question should be able to deal with the estimated increases. The repeated failure and unexpected problems related to cooling systems are still a matter of concern to our groups. We will expect that Licensees will monitor these systems with enough scrutiny to provide the necessary assurance of safety for employees and the public.
Intervenors understand that contentions must be framed in a technical fashion and feel that our ongoing concern will not meet those requirements. Therefore we ask permission to withdraw contention 4.
Submitted By Douglas Collins Communicator for Citizens for Safe Energy and The Quad Cities Alliance for Safe Enc"gy and Survival i
s CONTESTED CONTENTIONS 1.
Intervenors contend that the additional spent fuel assemblies which will be stored in the proposed high density spent fuel storage racks will increase the temperature of the spent fuel pool water and cause the cladding of the fuel rods to corrode, thereby endangering the public health and safety.
2.
Intervenors contend that the increased amounts of irradiated fuel in the proposed spent fuel pools will increase radiological releases from the pools and occupational exposures in the pools area.
In light of this, the present radiation monitoring system is inadequate to provide a reasonable assurance of public health and safety.
Specifically, reanalysis of the present system should be required and should consider:
increasing the capacity of the venti-a.
lation system, and b.
increasing the range, sensitivity and number of area radiation monitors, including Geiger-Mueller monitors, and monitors of the pool water itself.
3.
Intervenors contend that Licensees' appli-cation to install its proposed spent fuel storage racks should be denied, as a.
the durability and performance of the Boraflex in the spent fuel pool water environment is unknown and unsubstantiated, and ATTarHMTNT NO. 1
b.
the corrosion rate of the stainless steel in the racks is unknown, and may result in their struc-tural failure, thereby failing to provide a reasonable assurance of public health and safety.
4.
Intervenors contend that in light of the increase in decay heat which will result from the proposed increase in the spent fuel pools' storage capacity, the current capacity of the radioactive waste treatment and cooling system for the spent fuel pools will be inadequate for the proposed modification, thereby failing to provide the requisite assurance of public health and safety.
5.
Intervenors contend that potentially exces-sive occupational exposure will occur due to removal, dismantling and dispositon of the present racks, and instal-lation and routine maintenance of the proposed high density racks, in violation of 10 C.F.R. Part 20.
6.
Intervenors contend that the presence of bowed fuel assembly channels and bowed fuel rods at Quad Cities Nuclear Station will present an unacceptable risk of radiation exposure to workers and the environment during the reracking operation.
7.
Intervenors contend that the high density fuel storage, as proposed by Licensee will present an unacceptable risk to the public health and safety, because '
L' of increased consequences of the following accidents:
The consequences of the chimney falling a.
on the spent fuel pool containing additional spent fuel as a result of the requested modification; b.
The consequences of a fuel drop accident in the modified spent fuel storage pools; The consequences of a dropped fuel c.
assembly on the five special plutonium bearing experi-mental fuel assemblies in a spent fuel pool containing more densely compacted additional spent fuel as a result of the requested modification.
8.
Quad Cities Nuclear Station's quality assurance programs and inspection procedures which will be utilized during the insta31ation of the proposed racks and removal of existing racks are not set forth by Licensees with sufficient specificity to provide reasonable assurance of public health and safety during the reracking operations.
9.
Intervenors contend that the proposed racks are not adequately designed to withstand the Safe Shutdown Earthquake (SSE) and Operating Basis Earthquake (OBE) established at the operating license proceeding for the Quad Cities Nuclear Station, which could lead to the release of radioactive materials which would have a detrimental effect not only on the State of Illinois but on other states as well. - -
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