ML20049A406

Suppl to Petition for Leave to Intervene & Request for Hearing.Certificate of Svc Encl

ML20049A406
Person / Time
Site:	Clinton
Issue date:	01/14/1981
From:	Samelson A PRAIRIE ALLIANCE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20049A405	List: ML20049A404 ML20049A406
References
NUDOCS 8101230178
Download: ML20049A406 (10)

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NtK1 EAR REEUIMCRY COMISSIC14 ,i- .

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In the Mattar of ) ,,;..

) Docket Nos. 50-461 IILDOIS PGER CD1PNN, et. al. ) 50-462

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(Clinton Power Station, titits 1 ani 2) )

PPAIRIE AILING SUPPIDCC to ITS PETITICH FOR IIAVE 'IO UTTERVUE AND PECUEST FOR IGARUC Pursuant to 10 C.F.R. 2. 714(b) Petitioners, PPAIRIE AILING, DC.

ard S'IMCET EISASSER, inn *A EISASSER, JOMtE SQMMtr, JEMI IUf, CARCLDE  ;

immt, ard ALIR4 SAMEISCN, acting crt their own behalf ard as maters of Prairie Alliance hereb/ supplements t.%ir previously filed Petition for Imave to Intervene ard Bequest for a llearing.

As a preliminary matter, Petitioner calls to t.% Board's attention t.%

limitations under which this su;planent has been developed. First, Petitioner is actirq without the benefit of czursel. Second, Petitioner's access to essential doctanents has been restricted in t.%t the 19 voltane ISAR is available to Petiticner only during certain hours at the Applicant's local office and the frility += - its reczn. 2e feility PIR has similar time restricticms. M)reover, the NIC Staff has tot yet issued the Safety .

Evaluation Report for the facility. Discovery efforts will nest likely provide further basis for Petitioners' contenticns.

Petitioner's contentions are as follows:

1. Petiticners crritand that the Applicant ard Begulatorf Staff have not adequately assessed the irpact of the nunerous unresolved safety issues, in reviewing the Clintcn Units 1 ard 2 in conjunction with the operating license application. 2e Clinton systems, structures arxi crrponents wre not backfittai to meet current regulatory requirements for adequate crrpliance with 10 CIR Part 50.109.

2. Petitioners contend that t.% Applicant ani aegulatory Staff have tot adequately derrnstrated that the U eg of fuel and reiew-tive wastes to and frtan the Clinten site will crrply with 10 GR Part 71.

810 123ql~@ -

J For exmple, the Envircrrental Report does not adequately discuss the envirtrmantal effects of (a) the transportation of cold fuel to the reactor (b) the transportation of irradiated fuel frcn the reactors or (c) the transportaticn of solid rMhtive wastes frun the reactor.

3. Petiticners otmtend that the Applicant has not adequately chronstrated that the Clintcn Beactor omtalment Syste neets the requirerents of 10 CER Part 50, Appendix A, Criteria 4, lb, 50, 51, and 52.

Ibr exmple, the FSAR does not adequately consider the unresolvei issuss of ID2 hydrogen generation quantities dermstrated at "JtI thit 2.

4. Petitierwars contend that the Applicant has not developed adequate experirental data and McM sufficient testing to verify the centalment design in acmrdance with requirements of 10 CER Part 50, AEpendix B, criteria III and Criteria XI. . .

5. Petitioners cxmtend that the Applicant and Regulatory Staff have -

not adequately da:onstrated that the mergency Core Cboling Systen (ECCS) for Clintcm caets the requirerents of 10 CFR Part 50.46 and 10 CFR Part 50, Apperdix x.

, 6. Petitioners contend that the Applicant ard Begulatory Staff have not derenstrated that the result cf hirian error has been exaninsi as required by 10 CFR Part 50, Appendix A, Criteriens 19, 20, 22, and 29.

7. Petitioners mntend that the Applicant ard Regulatory Staff have not adequately demonstrated' that the Clinton nuclear systan reets the I requirerents of 13 CIR Part 50, Apperdix A, General Design criteria for l

l 2x: lear Power Plants.

l I 8. Petiticners a:nterd that the applicant has not derenstrated that the Clinton reactor contairrumt and supporting structure of the pressure vessel meet the requirerents of 10 CIR Part 50, Appendix A, Criteria 4, lb, 30 and 51.

9. Petitioners contend that Applicant has not yet developei adquate experimental data through testing in actnrdance with requirerient of 10 CER Part 50, Appendix B, Criteria III & XI to assure the verification cf the design throtsh a properly controlled testing prop.

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10. Petitioners cxntend that the Applicant ard Regulatory Staff have not adequately dronstratal that all credible or reasonably possible accident mechanians have been considered ani included in the design base as required by 10 CIlt, Part 50, Appendix A, criteria 14, 31, and 35.

11. Petitioners contend that the ecorrnic and social effects of staticn etnstruction and operaticn of Clintcn thics 1 and 2 have rot been adequately crnsidered in the Dwircurental Besort in that Applicant has not considered any new infocnaticn arising =%-t to the 1974 ccnstruction permit' review for the facility.

Petiticners cxnte.ti that the altermtive energy sources ard sites for Clintcn thits 1 and 2 have not bem adequately discussed in the Dwirorpental Report in that Applicant has rot considered any new infonnation arising subsequent to the 1974 ccrwuction permit review for the facility. .

12. Petitioners contend that the Staticn <*mign alternatives have not been adaquately discussed in the Envizorriental Report in that Applicant has not considered any new infor:naticn arising =W=nt to the 1974 cmstruction .

permit review for the facility. ,

13. Petitioners centend that the current simnary cost-benefit analysis for the C13nton thits 1 and 2 is grossly immrate in that Applicant has rot -

ocmsidered any new infor: nation arising =bmat to the 1974 construction permit review for the facility.

14. Petitioners cxntend that the ISAR is inadequate as a wtcle hew it has been sizabitted prenaturely. Ctnstructicn of Clinten (Mts 1 & 2 is l

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not yet far enough alcng to allow a cisaningful FSAR to be sutznitted.

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15. Petitioners contend that trea nuclear steam supply systan of Clinton thits 1 and 2 contains rarerous generic design deficiencies. Se of these j

deficiencies are presently unresolveir others are unlikely to be resolved by l

the time the Clinton thit 1 is considersi operable: still others may rurver be resolved. Ibr exxple, (a) Applicant has not adequately daxnstratal that the Clinton l

thits 1 and 2 Protection and Reactivity Otntml Systans cxrply in the matter of ATa5 as required in 10 CFR Part 50 App. A Criterion 20 and 10 CIlt Part 50 App. A Criterion 21.

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4 (b) De applicant has not adegaately dernstrated tMt the safety margins en the Clinton Nuclear facility core spray distribution systs are in cxrpliance with 10 Cnt 50 App. K.

(c) Similarly, the cracking of steel piping in BWR coolant water envizerrents due to stress mrrosicn has yet to c'r prevented or avoided.

(d) Applicant has not adequately decnstrated ti st the Clintcm Vessel support systan can adhere to 10 Cnt 50 App A IV Criterien 32 and 33 in the event of an asymetric blow down.

16. Petitioners ccntend that the Applicant has not adequately developed or r'amristrated a security plan for the Clinton thits 1 and 2 which ocmplies with 10 C.F.R. 73.55.

17. Petitimers contani that A;plicant does not possess sufficient ,

managment empahility as required by 10 C.F.R. 50.34(b) to assure that tM Clinten thits 1 and 2 will he (a) minuid in a safe cxnditicn while operating normally; (b) operated reasonably during a period of atreenal 3 occurrences occurring either seperately or in ecubinaticn; (c) deormissicned in a safe manner.

Past mi-Pt of the cxnstruction of Clinton thit 1 has been .

well doctrented in proceedings before the Illinois 02merce Ccumission and other publicly available docments.

18. Petitioners corteni that Applicant cbes not possess sufficient technical qualificaticns as required by 10 C.F.R. 50.34(b) to assure that the Clinton thits 1 and 2 will be (a) maintained in a safe ceniition while operating nonna11yr (b) operated reasmably during a period of abncemal

<w%.ss occurring eitMr separately or in sequence; (c) dectrnissioned in a safe nanr:er.

19. Petiticners cxmtend that Applicant does not possess sufficient finanical capability co assure tMt to Clinton I: nits 1 and 2 will be (a) ccntinuously operable in a safe and cost-efficient mnners (b) dectruissiensi in a safe and cost-efficient mnner. In addition, Applicant is not financially capable of assumirry the costs of an accident similar to that which occurred at Three Mile Island thit 2.

20. Petitimers omterd that the Agplicant has not adequately omsidered an accident of the t)pe tMt occurred at Three Mile Islard ,

- Unit 2 either in terms of the e of such an acx:ident, their effect on the cost-benefit analysis of the Clinton thits 1 ard 2 or possible measures to prevent or mitigate the occurrerice or effects of such an accident. .

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21. Petiticners conterd that the Applicant has ret adeqt.ately con-sideral the effects of low-level radiation ard other discharges to be released fztn the Clinton thits 1 ard 2.

i For exs:ple, only effluents antiMpated to be released fran Clinton Unit I were cmsidered in < almiatima estinating population doses.

22. Petitimers cxnterd that the Applicant has rot sufficiently considered the adequacy of the ung-ter:n uranitas supply for the Clinton -

t2iits 1 ard 2.

For example references in the ER -mh5 the relaticnship between fuel supply ard fuel constsption are unsubstantiated.  ;

23. Petitcriers centerd that the Applicant has rot adequately considered the need for power to be generated by the Clinton thits 1 ani 2 reactor.

For exmple, Applicant has consistently overestimatai the danard for power to be generatsi by the Clinton thits 1 and 2.

24. Petitic 1ers conterd that the Applicant Pas rot developsi a safe and feasible eciergency evacusticn plan to be utilized in case of a serious acx:ident at the Clinton Units 1 ard 2.

For exmple, the financial and persainel limitations of DeWitt County ard other nearby cunicipalities to fulfill the cbligations of an emrgency evacuatial plan have rot been sufficiently considered, te prchlens posed by the evacuation of special facilities, such as prisons and rental health centers, have also rce been adequately considered. ,

25. Petitioners contend that the Applicant has rot adequately considered the occupaticmal exposure ta radiation to be expected fran either the normal cperation of the Clinton thits 1 ard 2 or that which may oc::ur during an abrormal Occmme or a serious accident.

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26. Petitimers centeni that the Applicant has ret a$equataly damstrated reluctim of vulnerability of the Clintm thits 1 ard 2 to industrial sabotage, missile activity, airplane milision, a turbine missile, or natural cascatrcphies such as a tornado, eartiquake, ficod, or fire. .

27. Petitioners conterd that the psychological stress and treau to be anticipated in the aftermath of an w W nt of the tipe Wiich occurrai at IMI thit 2 is not adagantely canaidared in the ER.

28. Petitialers atritard that the applicant has not adequately dancmstrated in m !ianc= with 10 G R 50 App. A Criteria 64, that the Clintm thits 1 ani 2 radation acrtiterirq instzunantation is ' sufficient to int.ure public safety, particularly, but not cnly, during wWnts such as occurred at TIC thit 2. .

29. Petiticners entend that the electrical equipnent of Clintm thit I has not been deconstratal to qmMey for operation under wWnt ecrditions.

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30. Petitioners cxnterid that the centrol recn laput ard instncents have not been adequately backfitted to acmunt for an accident of the type which occurred at "MI thit 2 in empliance with 10 GR 50.109. ,

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31. Petitioners contend that an Emergency Operatices Facility has not been adequately developed and damstrated.

32. Petitimers contend that the applicant has not adequately,dsenstrated the capabilities of Clinton a m a cy syste s reliability in the absence I

of offsite pow _r.

33. Petitioners ccnteni that the Applicant has not adequately dcronstrated that the Clinten reactor coolant secondary systm occplies with 10 CE1t 50 App. A Criterien 30 ani Criterian 31. The design and fabrication of the Clinton thits 1 ani 2 pressure vessel, systen piping, valves ani etrponents were not developsi in m*nce with mrrent regulatory standards.

34. Petiticriers contend that the Applicant has rct adequately investigated the effects of neutron irradiation cm the Clinten nuclear reacter vessel material toughness in cmpliarx:e with 10 CFR 50 App. A.

35. Petitimers contend that the Agplicant has ret adequately deanstrated the capability of the inspectim of the reactor coolant ,

pressure boundary, especially in asaaaaing the margin against failure

.under various plant cmditions throughout the full life of the plant in ecztpliance with 10 CI1t 50 App. A Criterion 31 and Critericn 32.

36. Petitimers centend that the Applicant has not adapately '

demonstrated its ahitity in the matter of Primary Caolant Systan Deccm-tanination of the Clintcn thits 1 and 2 or in the matter of steun generator cWcal cleaning to emply with 10 CIlt 50 App. A Criterien 60, 61, and 64.

37. Petiticners corrtend that the Applicant has not adequately danmstratai that Clinton etntalment leak testing is in accordance with the revised 10 Cf1t 50 App. J.

38. Petitioners cxmterd that the Applicant has not adequately dexmstrated that the .~-1.?rn thits 1 and 2 have an adequate D.C. power systen in liance with 10 CFR 50 App. A Criterion 17, i

39. Petitioners centend t.%t the Applicant has not adequately de m strated taat all safety relief valve cambinations i.e., transient analysis has been ccraidered in the design of the Clintxm Units 1 and 2 cxmtaiment system in cW.iance with 10 Celt 50 App. A Criterion 50 and 55.

40. Petiticrera contend that the Applicant has ret detonstratsi t.%t spent fuel in storage or in the reactor core is adequately abialdM frcn heavy inada. Release of radinactivity resulting frcn omvjed fuel rods fztn heavy loads ma,e ci/er waie pht personnel er the envht. %

the environment. This is not in ecxrplianm with 10 CFR Part 100 guidelines.

41. Petitioners contend that t.% Applicant has not adequately dmonstratsi in cmpliance with 10 CFR Part 50 Appendix A Criterion 30 that the piping and valves of the Clinten thits 1 and 2 are sufficiently protecteri frcn possible water hamer incidants.

Pespectfully sutnitted,

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Allen Sar:ielson, Pepresentatlw for Prairie Alliance, Inc.

P.O. Box 2424, Station A Charrpaign, IL 61920

CDCIFICME OF SEWICZ I hereb/ certify that an Original or cx3py of PFAIRIE AEIMEE StlPPIDec 'Io ITS PETITICH ftR IJAVE 'IO I CE1WDE RD REUJEST IUR HEMtDE has been served on the t,llowing by deposit in the thited States Mail, postage pr v id, on January 14, 1981.

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Secretary of the Omnission

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U. S. Nuclear Regulatory Cm mission ,N .

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Attention: Docketirq and Service Branch 9

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Exec 2tive Imgal Director U.S. Nuclear Regulatory CTmission f .* ' ' % > D '

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R' Washington, D.C. 20555 , . . * -/-

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Philip I.. Willman N -

Assistant Attorney General ,,/,7[* '

Dwirorsnental Cantrol Divisim 188 West Randolph Street Suite 2315 Chicago, IL 60610 Peter V. Fazio, Jr.

Schiff, Hardir. ani Waite 7200 Sears 'Ibwer 233 South Wacker Drive C11cago, IL 60606 ,

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,m-G Auen S.unelsm, RepresentatAve for ,

Prairie A11iance, Inc.

P.O. Box 2424 Station A Chepaign, IL 61820 -

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P:2L UNITED STATES OF AMERICA Til NUCLEAR REGULATORY COMMISSION , , _ , _ ,

In the Matter of )  ::EEE

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~~~I ILLINOIS POWER COMPANY ) Docket No.(s)50-46h

) 50-462 _, ,

(Clinton Power Station, ) -

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. Units 1 and 2) .

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y CERTIFICATE OF SERVICE . .fj I hereby certify that I have this day served the foregoing document (s) upon each person designated on the official service list compiled by ;lg-the Office of the Secretary of the Cor:::nission in this proceeding in . .;.;;.; ~

accordance with the requirements of Section 2.712 of 10 CFR Part 2- . - - .

Rules of Practice, of- the Nuclear Regulatory Co=:sission's Rules and .

Regulations. . f.,7,7l,

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Dated at Washington, D.C. this

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QQh h. Q 5 Of fice/ df / he Secretary of the Co'::::nission t

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UNITED ST.ATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

                                                   )

ILLINOIS POWER COMPANY, ET AL. ) Docket No. (s) 50-4610L

                                                   )                      50-4620L (Clinton Power Station, Units 1 and 2)   )*
                                                   )
                                                   )
                                                   )

SERVICE LIST Hugh K. Clark, Esq. Philip L. Willman, Esq. P.O. Box 127A Susan Sekuler, Esq. Kennedyville, Maryland 21645 Assistant Attorneys General

                               ,                        Environmental Control Division Dr. George A. Ferguson                        188 West Randolph Street, Suite 2315 School of Engineering                         Chicago, Illinois 60601 Howard University 2300 Sixth Street, N.W.                       Reed Neuman, Esq.

Washington, D.C. 20059 Assistant Attorney General 500 South Second Street Dr. Oscar H. Paris Springfield, Illinois 62701 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Bloomington-Normal Prairie Alliance Washington, D.C. 20555 ATTN: Mr. Jeff Urish . 703 Wilkins - Counsel for NRC Staff Normal, Illinois 61761 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Prairie Alliance Washington, D.C. 20555 P.O. Box 2424 Station A Peter V. Fazio, Jr., Esq. Champaign, Illinois 61820 l Schiff, Hardin and White 7200 Sears Tower 233 South Wacker Drive l Chicago, Illinois 60606

Illinois Power Company I

ATTN: Mr. L.J. Koch Vice President 500 South 27th Street

Decatur, Illinois 62525}}