ML20049J176

Partial Reply to First Set of Interrogatories.Requests Parts A,B & C of Contention 7 Be Withdrawn

ML20049J176
Person / Time
Site:	Quad Cities
Issue date:	03/08/1982
From:	Dan Collins CITIZENS FOR SAFE ENERGY, QUAD-CITY ALLIANCE FOR SAFE ENERGY
To:	COMMONWEALTH EDISON CO.
Shared Package
ML20049J175	List: ML20049J174 ML20049J176
References
ISSUANCES-SP, NUDOCS 8203120218
Download: ML20049J176 (4)

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pf l Citizens For Safe Energy 47 P.O. DOX 23

',4' . HILLSDALE. IL 61257 Il e Cochairpersons Artyn Dad - Ere. it 1, i Boo Mdier - Chaton. l A a Secretary Marilyn 80s - Hallsdae,1L

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/~ $ froasurer Phylles Hohenboken - Hillsdale.lL

• 4 Board Members Deanes Helfer - Prophetstown. lL 4i  %"; ) -

Jarn Jacobs - coneseo,IL J .

h#p g . Lantz Ropp - Geneseo.lL f }l ' iff.'.e FI..-

i 3 1 Jack San:th Rock tsland.lL T ,l t3'D.F - xaren vro, nan - o4e. it

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In the n'atter of ) Docket Nos. 50-254-SY

) 50-265-SP Commonaealth Edison Company )

(Quad Cities Station, )

Units 1 and 2) )

Citizens for Safe Energy's and the Quad Cities Alliance for Safe Energy and Survival's partial reply to Co.monwealth Edison Company's and Iowa-Illinois Cas and Electric Comrnny's First Set of Interrogatories.

Contention 7:

A. Intervenors believe the letter from James R. Mcdonald of Mcdonald *tehta and Minor .

Consulting Firls and the Vant St ack Re-Analvsis Report for the Quad Cities Nuclear Power Station was helpful in sking a decision on Nrt A of Contension 7. It is stated in the conclusion of the Vent Stack Re Analysin Heoort that is would be theoretically possible for a portion of the vent stack to fall into the spent fuel pool.

Intervenors believe the addtional proposed spent fuel could be critical in case of an accident involvin6 the vent stack. However, Intervenors believe the additional purposed spent fuel will not make a vent stack accident more likely.

Intervenors request to drop Part A of Contention 7.

3. - C. The Intervenors have extensively researched Special Report #28 and Addendums 1 and 2, Analysis and Procedures fcr Handline General Electrie IP-300 Spent Puel' Shiceine Cask. ihe Intervenors believe modifications of the reactor building crane should stop any cask drop.

The Intervenors believe the process of placing the spent fuel in the proposed high density racks in the pool should be done in a safe and acceptable manner, not only for the worker's safety but that of the general public as well.

The Intervenors request to drop Part 3 & C of Contention 7.

Subcil ted hpMN gY Douglas all s Communicator for Citizens for Safe Energy and The Quad Cities Alliance for Safe Energy and Survival 1

8203120218 820308 PDR ADOCK 050002S4 G PDR

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• 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:

a. increasing the capacity of the venti-lation system, and

b. increasing the range, sensitivity and o

number of area radiation monitors, including Geiger-

! Mueller monitors, and monitors of the pool water I

itself.

3. Intervenors contend that Licensees' appli-I 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

(. .jb' unknown and unsubstantiated, and l

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Jf 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 l

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

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of increased consequences of the following accidents:

a. The consequences of the chimney falling 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;

c. The consequences of a dropped fuel 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 modificatio:-

8. Quad Cities Nuclear Station's quality assurance programs and inspection procedures which will be utilized during the installation 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

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