ML20041G407
| ML20041G407 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/10/1982 |
| From: | Mills C KANSANS FOR SENSIBLE ENERGY |
| To: | NRC |
| References | |
| RTR-NUREG-0878, RTR-NUREG-878 NUDOCS 8203220218 | |
| Download: ML20041G407 (10) | |
Text
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r iri A R CH 10, 1982 I n t r m d i; c *.10 i:
an,.nu for at:nci al,: Usergy,
<AaL, trU interVunUrb in the Up-e r o *, i n. ; licenne n e.a r i n:;G for the UDlf Creek genera ti ng station.
As n group un support conserva tion and consumerism in the el-ec t ri c a l enur ;y fiuld, and appone th.. r; r a n t. i n g of an operating 1ict nst.
In tnis te;ponse to the "J: aft. L n v i r o nsie n t.a l State-
'nent" Inlated to t h i. operation of la l f Creek Cenurating Station,
.JnL3-lt71, Kit.it offers so,n o ot> s u rva t i o ns Jac et i d T N 5 'J
'.12,
ror Lt.e consideration of the, ii C, and s o.ri e c.a t e r i a l we thi nk should bc:come a part of the final draft statement, f or the o n '< e of brevity, un uhall confine nur c o m m e n t. s to three gon-eral n ea n :
1.
.uud for the electricity provided by QCCS 2.
Assensment of p o t. e n t i a l risk o f' accident ii i di ol o g i ca l impact of fuel cy:1> on environment 1.
.LEJ Fun THE ELECTRICIT( P n t; V I JL WC35.
In section 3 of the draft e nvi r an.r a nt a l s
- c. u:n e n t the staff concludos thal
"...tne only logical alternative to operation of the station in to anny its operation."
Le agree that if the ji n.
c.J, app, two billion dollars of constroutivo n 2 '.
i l u.L r r.o u n t p.iSive ur t,
.co.A
.in
- 1 e.s t
of electric'l enorgy.
Howevar, this does not address thu questiuo of. hot 1t: :. ' i e 115;a.Ce to ao p roduced t2 y u,CCS is O
hIb B203220218 820310 1
PDR ADOCK 05000482
)
D PDR
actually needed.
On page 2-3, taole 2.1 compares the opera-tiori costs of iCG5 with the opera tion costs of replacement p o u. e r.
Since th e p or.sibility exists that no replacement power is needed, a third catagory should be added listing "Produc-tion costs if no replacement power required".
Of course, the costs a ssocia t ed with this alternative will be zero for each y ea r i ncluded i n th e toole. Another line should be added, "Sav-ings with WCG3 not in op era tion".
The figures for this line would ce tne total nucl ce r produc ti on ccut far e.e c h y ea r in-clod.
in e ts' 10
_ith the inclusion of these lines to table 2.1, the primary question becomes is the electrical power to be gen-erated by u;CCS needed?
There are many reasons to expect that demand for electrical energy will level off or decline.
ciuch of the growth in peak demand in the '70's is attributable to all-electric home, and electrical hea ting in residential use.
Grouth in these areas has virtually ceased due to lack of de-mand for all-t1tctric num s.
R rt of this drop in dn and ic
,_1:
or r leveling of residential electrical rates, elim-i n: t i n.,
rate structure designed to reward wa ste and offer owners of all-electric homes reduced rates.
As prices go up and conservation continues to make a " surprising" difference between load f orecasts and actual increase in demand, usage and peak dema nd will decline.
If the utilities would, i nst ea d of encoura ging consumption, foster conservation th rough the use of load ma na g em e n t technology, demand would fall even more.
Which brings us to page 2-6, table 2.3.
This amoitious table forecasts rate of demand growth for the next eight years.
Since the applicants have overestimated this same rate each year for the past ei gh t y ea r s, this table calls for a closer exa mi na ti on.
KASE recommends that the f ollowing taole, table 2.3.0, be added to the final draf t report:
Ta bl e 2. 3. J Peak A nnua l Caoacity (u.ee)
H es er v e n.a r ai n ( fl)
Demand iiate of Without With Uithout with Year (inu e )
Growth (f)
CCGS WCG5 UCCS UCCS KGE 1994 1785 2111 2652 18.2 43 1985 1812 1.5 2111 2652 16.5 46.4 1986 1839 1,5 2247 2789 22.2 51.6 1987 1867 1.5 2247 2788 20.4 49.4 1988 1995 1.5 2247 27SS 18.6 47.2 1989 1922 1.5 2247 2785 16.9 45.0 1990 1951 1.5 2247 2788 15.1 42.8 KCol 170-2485 2804 3265 12.8 31 1985 2535 2.0 2304 3265 10.6 26.8 1986 2585 2.0 2004 3265 9.5 26.3 1987 2637 2.0 2004 3265 6.3 23.8 1968 2690 2.3 2B04 3265 4.2 21.4 1989 2744 2.0 2304 3265 2.2 19.0 1990 2799 2.0 2764 3225
-1.3 15.3 This alterna te table gives the va riables of taole 2.3 uith a new 5 rate of growth.
KASE feels these rates of grottn are very possibly too high, certainly current trends would indicate a long p eriod of very small grotth f or th e next decade.
..o t e,
according to the table, KCE will still have a 15% overgenerating capacity without
'2 C C S i n 1993.
In the draf t statement, staff
4 recommends utilities keep " minimum reserve margins at 153" (pg 2-5).
Wh en p eak d en.a nd wa s increasing 54-73 each y ea r,
such a reserve was necessary; but now with a leveling p eak,
a reserve of 103-123 should be sufficient.
It is interesting to note on the alt ernat e table, that in 1938, although KCPL uould be down to a 4.2j margin, KGE would still have a 13.6) margin without '1'C G S.
Since KGE could sell some of its excess reserve to KCPL, if needed, both utilities vould have an adequate reserve.
If, indeed,we do see a leveling off trend in demand growth, NRC will be in a position to delay the operating license until 196B.
This would allow the commision to see what demand growth uill turn out to be for the next five years, and the applicants will still have adequate reserves.
Si nc e construction costs are not included in this study, the i nc r ea s ed construc-tion costs associated with delays in bring khe plant on-line cannot be considered.
Delaying the applicant's license will be cost-free, will save Ou, costs from 1984 to 1938, will leave th e utilities adequate reserves, and will allow the commission to lea rn dema nd trends for an additional five years.
2 ASSESS.nEi4T OF POTE JTIAL RISX OF ACCIDENT Although ma ny studies are cited to support the contention that electrical transmission towers only rarely impale hawk s a nd eagles, only one s.tudy is cited to determine the probability and risk of a major muclear accident.
In regards to the effect of a class nine accident we do have another study thich can be cited in addition to RSS.
This is the AEC (ncuNdC) drook-haven report, Wash-743.
Th e fact that ma ny reports are used to study a relatively small proalem, while available reports
5 relating to the most serious possible problem are ignored is a major weakness in the draf t statement.
Wash-743 found a worst cast accident could cause 45,000 deaths, injure 1)),000, a nd cause 317 billion in property damage (1955 dollars).
Th e first draft of RSS refuted these cosequences and found the result of a class 9 accident to be much less.
After criticism of RSS by the America n Physical Society, EPA, and others, RSS reevaluated the potential worst case effects at 3,300 early deaths, 45,000 early injuries, and 314 billion property damage (USNRC Oash-1400 (NUREG 75/014) pg 107 ).
Although RSS is the only study cited, this important conclusion is not directly given in the draf t statement and referred to only indirectly in the graphs of probability.
This conclusion should be in the narrative of th e final sta t ement.
HSS model reactor was twice the size of the drookhaven study model reactor, yet RSS found less damage due to a worst case accident, If RSS is to be the ultimate authority on risk assessment, the final statement should address th e disparity between Wash-1400 and uash-740.
RSS probability estiuation techniques nave received even more criticism than RSS consequence estimation.
Every tacle and nraph from p'g 5-50 through pg 5-63 ha s a footnote directing the reader to section S 9.4.5(7) for " discussions of uncertaintics in risk estimatus".
However, when the reader referres to that section, he does not find a critical discussion of RSS estimation t ech ni que 's shortcomings.
I ns t ea d, a Lewis r ep o r t fincing is given:
"Th e meth odology, which wa s an inporta nt advance over earlier methodologies that had been applied to reactor risk, was sound."'
A more thorough discussion of RSS shortcomings
6 can be found in the American Physical Society's Reviews of idadern Physics, vol 47, supplement dl, "Heport to the APS by the Study Group on L1R Safety".
KASE recommends that this report, in tot 4( be included in the final statement.
Reliability estimation techniques used by RSS were developed by nAS4 to compa re the reliability of two or more diferent sy stems in relation to a problem.
Tn e " odds", or probacility of occur-rence, give a good measure of one systems advantages in relation to a different system.
The odds do not give a good neasure of an individual system's probability to fail over a period of time.
Th e tech nique wa s never mo" to give such information.
In spite of this, we find on page a-64: "The accident at Three hiil e Island occurred in uiarch 1979 at a time when the accumu-lated experience record was about 400 reactor-years.
It is of interest to note that this was within the range of frequencies estimated by the RSS for an accident of this severity."
In 1970, Commonwealth Edison's Dresden II plant in ;norris, Illinois was out of control for two hours.
A study by the Sierra Club and the Union of Concerned Scientists, " P qli mi na r y Revieu of the AEC Reactor Safty Study", Nov. 1974, used RSS estimating tech-niques to find the probability of the Dresden accident cccurring.
The result was that the a ccident unicn hac already happenec had a proaability prediction of one in a billion-Dillion.
On page S-42 staff states: " Accidents have also occurred at other nuclear reactor f acilities in th e Unitec States anc in otner countries....u.elting of reactor fuel ocurred in at l ea s t seven of these accidents, including the one in 1965 a t the Enrico Fermi Atomic Power Plant U ni t 1."
Tin i i s not the only severe
r 7
accident in the nuclear industry's accumula ted experiance record. I n Ja nua ry, 1961, the SL-1 reactor in Idaho falls went out of control killing three workers, impaling one on the ceiling with a control rod.
In 1975 the drown's f erry pla nt near Decatur, Alabama suffered a seriour fire.
Although the fuel rods were not damaged, the fact that the fire lasted seven hours, and th e repair bill wa s over 3150 million cer-tainly qualifies Brown's Ferry as a serious accident.
Thousands of accidents occur each y ea r, ranging in sev eri tyfrom r ela ti v ely mi no r to the loss of thousands of gdlons of radioactive water, as happened at the sonticello, Winn. plant in Novemoer, 1971.
All these accidents c uli u strff's alend assertion that fi.. I
.5 no isolated incident that ncally fits into RSS probability estimation.
A second problem with staff's statement is that the 400 years of accumulated r ea c t o r ex p e ri e nc e includes an over-abundance of early plant operation.
luclear power plants, as with all other industrial ooerations, operate more e f ftci e nt l y when new than wh en old.
Th e a ccumula t ed work experience f' rom 500 years to 1000 years should provide a more accurate litmus test of reactor reliability.
Another problem is related to this one.
This is the problem of em brit t l en e n t, which is only now coming to the attention of the nuclea r industry, and which is not addressed directly in the draf t statenent.
Embrittlement is metal fatique caused oy radiation exposure.
Recently it has :een reported that NHC has found 3 plants in 7 statua with reactor shells suffering with various stages of c:.icrittle-ment.
It is also becoming mora evident that this is a casic problem i nh e r e n t to the fission process which will affect all
U nuclear power plants af ter a dozen or so years of operation.
Obviously, embrittlement poses not only a serious risk of ac-cident, but also a foreshortening of reactor plant life.
Th es e serious considerations are not addressed in the draft s t a t ein e n t, and th ei r omission is a serious sh o r t c o.ti n g,
dased on the preceding discussion, KASE concludes that the RSS con-sequence modeling and estimation techniques are unrelicole and overly optimistic.
Th e da ta summarized in table 5.9 is, therefore, based on unsupported assumptions, hence invalid.
If staff adheres to thu uau cf the Rh figures, K;st rec
.oends another section be added to seriously discuss " uncertainties in risk estimates".
KASE recommends this section be written by John Corman and/or Arthur Tamplin at applicant's expense.
3.
RADIGLOGICAL IhPACT CF FULL CYCLE CN ElTJIr4UNmLWT Th e radiolon' cal impact of the uranium fuel cycle is a large and difficult problem.
Taolo S.11 (3.3) shows the quantity of Rn-222 released to the environment as " Presently under reconsideration oy the C o m,;a i s si o n ".
Radon gas exposure to miners, people who live nea r iailling op era tions, and to people who misuso mill tailings in construction of homes is a serious question not sufficiently addressed by the draft statement.
The expense and practicality of k eeping anitoals out of c o n t a c.-
inated ernas af ter a serious accident or decommissioning is en-other question not resolved in the statement.
K ASE will confine our main criticism to the area of high-level a nd t ra nsura nic wastes.
From the draft statement, appendix G, pg G-9: "The
d 9
Commission notes that high-level and transuranic wastes are to be buried at a Federal repository, and that no release to the environment is associated with such disposal."
UUviously not all th e material removed from the reactor in the form of spent fuel rods will be lowered into the as yet unknown Federal re-pository.
The process of nuclear decay will mean that the material ent e ri ng the Federal repository will oe less than 103 ! of the material removed fro.. the reactor.
Th e real question is how much material unaccounted for (J,UF) there will be.
Of course there will be factors other than nuclear decay contri-buting to th e niUF p roblem.
Taole 5.4 pg 5-26 gives the rad-iological effects of accidents in transportation as"small".
How small will the risk of accident be when the Feaeral repos-itory finally does come into being and the overcrowded temp-orary swimming pools begin emptying thousands of tons of spent fuel rods into th e traffic patterns of America?
Leaving aside the question of whether the Federal repository will successfully isolatc high-level wastes f or the thousands of years necessary, the more serious question is how much of th ese wastes till be lost on the way to the repository?
To judge how effectively these wastes will be managed, we need to review how they have been managed in the past.
Plutonium released during a fire at the Rocky Flats Nuclear Teapons facility in may 1969 uas later found in soil samples taken in the metropolitan Denver area.
After having been r ep ea t edly cited f or allowing workers to become excessively contaminated, the West 'Ja l l ey, N.Y.
NFS reprocessing pla nt was closed in 1971.
High-level wastes i n. -
10 properly buried on-site, and still there now, have contaminated nearby creeks, notably the Ca tta ra ugus.
Th e 6,a x ey fla t s ar ea near Norehead, Kentucky has also contaminated nearby streams with high level wastes leached through the soil from " permanent" burial spots.
It is estimated that the Hanford Storage f acility in Richland, Wash. has Itaked 430,000 gallons of high-level wastes over a period of 20 years.
The U.S. has been producing high-level wastes f or nearly 40 years.
Uith the exception of those wastes which have already been " lost", that is released into the environment,none of this high level waste is permanently disposed of.
How much of this waste will ncvar reach a pcc-manent resting place?
A 1000 n.U nuclear plant can be expected to produce 30-35 tons of spent fuel cach year, 40J to 500 pounds of this waste vill be plutonium.
If we assume the most conservative, WGCS uauld produce 30 tons of waste af which 400 pounds would be plutonium eacn year.
uver tne course of its predicted 30 year lif e span, it would produce 900 tons of high-level fission products, with 12,000 pounds of plutonium.
If 99% of this material actually reached the Federal repository, 9 tons of waste, including 120 pounds of plutonium would be unaccounted for.
If 99.9j were accounted for, there could still be nearly a ton of waste with 12 pounds of plutoniu.a unaccouted for.
It is the opinion of KASE that a.1j..Uf will oc dificult if not impossiale for the nuclear i nij s t r y to maintain.
Jith
.1) auf of high-level fission procucts 72 operating plants, a
would mean nearly 77 tons of missing material over a 30 year p eri od.
Fi na lly, KASE recommends that a fi na l environmental statement ce delayed until after the federal repository is in oaeration.
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