ML20052A282

Motion for Leave to File Contentions 17,18 & 19.Certificate of Svc Encl

ML20052A282
Person / Time
Site:	Perry
Issue date:	04/22/1982
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8204280128
Download: ML20052A282 (12)

Text

UNITED STATES OF ANERICA ^ E- __

NUCLEAR REGUI).TCRY COMMISSION Before the Atomic Safety and Licensint Board In the Matter of  !

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CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 COMPANY, Et A1. ) 50-441 " *

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(Perry Nuclear Power Plant, )

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OHIO CITIZENS FCh RESPONSIBLE ENERGY MOTION FOR LEAVE TO FILE ITS CONTENTIONS 17, 18, AN rhe p

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Ohio Citizens for Responsible Energy ("0CRE") hereby moves the Licensing Board to grant OChE leave to supplement further its Petition to Intervene by filing its Contentions 17, 18, and 19 in the above-captioned proceeding. They are entitled respectively, " Substratum Placement of Water Intake Structure", "Use of Commercial Spent Fuel for Nuclear Weapons",

and " Polymer Degradation from Radiation Exposure."

This Intervenor will first provide general explanations for each contention; OCHE wil' then address the filing require-ments of 10 CFR 2.714.

Contention 17: Substratum Placement of Water Intake Structure OCRE contends that the latest water intake system proposed by the Applicant in its design for PNPP (ER-OL, Section 3.4.4) will inflict unacceptable damage to the aquatic ecology of the site and the Central Basin cf Lake Erie. The intake system I

planned for the Grand Gulf station (of which this Intervenor has recently learned) could well be a superior and environ-mentally preferable method of extracting the necessary water for PNPP.

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At the Construction Permit stage the AEC ASLB, the NRC Staff, and various commenters on the DES-CP all expressed concern that the Applicant's intake s'ystem designs would cause excessive impingement /entrainment of fish, fish eggs,

'and larvae. In the recently issued DES-OL (NUREG-0884), the Staff, on the basis of data collected at other power plants on Lake Erie, concludes that impingement /entrainment impacts at PNPP will be insignificant in comparision to the losses caused by other plants (DES-OL at 5-11). Impingement / entrain-ment losses at PNPP are predicted to be comparable to those observed at Davis-Besse (see Table 5.2, DES-OL).

OCRE notes, however, that although these losses are indeed less than those occurring at other plants, they are not neg-ligible. These losses need not be accepted, as the Grand Gulf design is far superior in this regard. As the FES-OL for the Grand Gulf Nuclear Station (NUREG-0777) at Section 5.6.1 succinctly points out, "because water is not removed directly from the river, no impingement or entrainment of organisms will occur." OCRE inquires as to why a similar system could not be incorporated at Perry.

The Grand Gulf design incorporates five radial wells (see Attachment 1). Collectively they will withdraw 41,900 gallons / minute. The water requirement at PNPP is somewhat higher: 69,400 gpm (ER-OL at Section 3.6.2). This Intervenor surmises that it may be possible for a well system to be successfully employed at Perry, given the construction of additional wells.

OCRE further suspects that the stratigraphy at the site

c may be quite suitable for collection wells. According to the PNPP FES-CP, Section 2.4.2, the strata located between the surface and the shale. bedrock some.55-61 feet below is comprised of "two tills and then lacustrine deposits." The depth and composition of this strata could lend itself well to the " induced infiltration" the Grand Gulf plant will employ.

The benefits are most notably the infliction of zero impingement and entrainment losses upon Lake Erie. The costs to achieve such benefits must be examined. The Applicant has apparently not done this.

Contention 18: Use of Commercial Spent Puel for Nuclear Weapons In October 1981 President Reagan lif ted the ban on com-mercial reprocessing of spent fuel imposed by the previous administration. Subsequently, there has been much speculation that as a result of this policy, plutonium from civilian reactor spent fuel will be used to make nuclear weapons. This spec-ulation has been fueled the development of laser isotope separation technology, which makes such utilization more feasible by removing the undesirable plutonium isotopes (Pu-238, 240, 241), leaving highly pure (93.5%) Pu-239, which is the preferred isotope for use in weapons. This speculation has also been fueled by various statements supportive of this plan made by high-level officials in the Department of Energy, including DOE Secretary James Edwards.

The Applicants apparently share Secretary Edwards' enthu-slasm for this plan, as is evidenced by an article ( A ttachment

2) appearing in "The Motor," a monthly magazine for CEI employees.

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_4 OCRE thus suspects that plutonium produced in the operation of PNPP may be used to produce nuclear weapons.

If, in addition to generating electricity, Perry will i

operate as a production facility for nuclear weaponry, OCRE contends that the effects of this must be considered under the National Environmental Policy Act (NEPA). Since the scope of NEPA is broad, an analysis of such action should not be limited to the radiological health effects of reprocessing, plutonium extraction and refinement, and weapons fabrication, but should examine societal consequences as well. E.g., an analysis under NEPA should examine whether this action would increase or decrease national security. Similarly, in accordance ,

with the recent court decision in-the TMI-l restart case re-quiring the NhC to consider psychological stress under NEPA, j the psychological effects on the Applicants' customers should l~ be. examined; e.g., some ratepayers may have moral objections r

to financing nuclear weapons production through their usage of electricity.

OCHE recognize's that such matters have been traditionally left to the Defense Department. However, since ours is a government of, by, and.for the people, and, as is evident from even a cursory glance at the news media, many American citizens

! are questioning defense policies relating to nuclear weapons, .

it is possible that this tradition may be changing. OCRE there-fore believes that the inclusion of this issue in this proceeding is appropriate.

I

' OCRE of course realizes that the use of commercial spent fuel to make nuclear armaments is not current policy. However, t

PNPP.will be licensed to operate for 40 years (indeed, the Pu-239- produced therein has a' half-life of 24,000 years);

it is difficult to predict' events 40 y, ears hence (let alone 24,000 years). From the indications given above, OCRE believes that this plan may be enacted within the operating lifetime of PNPP, possibly even in the near future. Licensure of Perry is under consideration now. The NRC Staff has already performed 4

its preliminary evaluation under NEPA of the impacts of PNPP operation, the DES-OL, NUREG-0884, which did not address this issue. A final statement is due within the next two months.

OCRE contends that the effects of using spent fuel from Perry for the production of nuclear weapons must be considered under NEPA in the current NRC evaluation of FNPP, and a cost-benefit l analysis be' prepared pursuant to such action.

If this cost-benefit analysis indicates that such action is undesirable, the Commission should impose a licensing con-dition specifically prohibiting such use of spent fuel' produced at Perry. If such a licensing condition cannot, for some reason, be imposed, then said use of : spent fuel should be assumed to occur, and the NEPA evaluation should be -incorporated into the cost-benefit analysis used for determining the desirability l

of plant operation. -The Commission's decision on the licensing of PNPP should thus be based accordingly.

Contention 19: Polymer Degradation from Radiation Exposure OCRE has learned of recent experiments condue:ed by-Sandia National Laboratories which indicate that polymers degrade more rapidly when exposed to lower levels of radiation

for long periods of time than when exposed to high levels for

. shorter periods. Since the latter conditions are used for i

age testing materials used in nuclear p~ower plants, it is possible that the useful life of such materials in a radiution i

2 environment has been greatly overestimated. Science News, March 27, 1982 at 215 (Attachment 3).

OCHE has not found in the FSAR a comprehensive listinE of all polymers used at PNPP which will be exposed to radiation and the methods used for age testing same, so this Intervenor -

cannot now determine the degree to which this concern is applicable to-the Perry facility. However, such matters are clearly appropriate subjects for discovery.

OCdE is concerned that the radiation-induced embrittlement of polymers, especially those used as electrical insulation, i

may compromise plant safety. OCRE therefore contends that all polymer materials used in a radiation environment at PNPP should be tested under realistic conditions and inspected for degradation at increased intervals throu6 hout the plant's life-time.

Section 2.714 Filing Requirements for Contentions 17, 18, and 19 OCHE offers as " good cause" for its non-timely filings the novelty of the information upon which the contentions are L f

based. The Grand Gulf design for water intake structures proposed in Contention 17 was described in the FES-OL for

, Grand Gulf, which was issued in October 1981, and was not received by this Intervenor until recently. Likewise Contention

, 18 is based on changes in government policy occurring in i

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recent months. Both of these issues should have been con-sidered in the DES-OL for Perry; the lack of assessment therein also constitutes good cause. . Contention 19 is cased on an article appearing in the March 27 issue of Science News.

The above-captioned proceeding represents, as has been mentioned previously, the only forum in which OCRE can con-veniently and expediently deal with these matters.

No other parties to this proceeding have voiced any concern about these significant matters; OCRE's participation will surely aid in the development of a sound record. Although the inclusion of othese contentions may broaden the issues, the extent of delay resulting thereby is highly speculative. Since the evidentiary hearing is not scheduled until November of this year, and this Intervenor expects slippage at that, there should be no delay-or resulting prejudice to the other parties by the inclusion of these matters in the proceeding. These factors thus favor the admission of these three contentions into this proceeding.

Respectfully submitted, eb Susan L. Hiatt OChE Interim Representative 8275 Munson Rd.

Mentor, OH 44060 (216) 255-3158

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It wasn't too long ago that the term wastes, to the average American, meant the rubbish, garbage and other trash you stuffed into a plastic bag and left outside for the sanitation department to pick up.

their decay is so rapid, that and is in use in other major he only contro- Anti-nuclear groups, 7 d 3 versy once gen- meanwhile, have been using it is not considered industrial nations. America's reprocessing program has erated by wastes the waste management issue hazardous. been delayed by political l was the typical in their arguments against The realissue of public concern is high-level radio- considerations, not through i family argument nuclear power plants. any lack of technology.

"" over whose turn Unfortunately many of their actise wastes that come from one source-the fuel = Reprocessing nuclear it was to take it out. arguments are based on misconceptions and in a nuclear reactor, whether wastes does not add to the Today, greater public radioactivity on our planet.

awareness of modern tech- exaggerations. it's used for commercial power generation cr for the In fact,it ultimately reduces nology coupled with concern the radioactivity that nature for the environment have Radiation levels production of national would otherwise be produc-given new meaning to the defense materials.

ing from the natural dis-Two types of rad.ioactive There are some facts

- term wastes. integration of the uranium wastes are produced by about these high-level The public isjusti5 ably nuclear power plants-low- in the earth.

concerned about the gase, wastes we should all know level and high-level. from the onset:

• The waste issue should ous. liquid and solid wastes In the category oflow- not be viewed as a dis-from industry that can pre. level wastes are protective advantage of nuclear power.

sent a health huard. New Basic facts garments worn by workers, it is one of the benefits.

laws and regulaticia now . Nuclear power plants Nuclear power produces a sludges, filters, retired govern the storage, shy . cquipment, clean up are not the major source of far smaller volume of wastes ment and disposal of such high-level radioactive than that produced by coal-l,i quids, and other industrial wastes. trash that may contain very wastes. In terms of volume- fired generation. And the Wastes from nuclear smau amounts of radioacti- more than 90 per cent of toxicity of nuclear wastes power plants are similarly vity. Such material can be such wastes in our country decreases with time. Chem-an area of public concern. easily packed in drums and today come from the ical waste toxicity remains In fact. recent polls have ,

national defense program, forever.

shjpped to designated burial shown that support for . The technology to re- A 1000-megawatt nuclear sites.The radiation levels in nuclear power is closely this material are so low, and process and ultimately tied te public confidence in isolate such wastes from the the nuclear industry's environment already exists ability to deal with its w astes.

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plant, for example, produces separated ;'utonium-a raw being injured by radiation Die hard critics of nuclear only enough high-level material fce atomic exposure. By contrast, there power pl. nts like to claim wastes a year to fill two weapons-could result in - have been iryuries, even that this industry is burden-telephone booths. nuclear ar s proliferation. fatalities, from the hundreds ing future generations with By contrast, each year the Other natons with of shipments each day our nuclear wastes. The nation's other industries nuclear po-cr plants - involving.flammables, ex- fact is that these wastes produce a volume of toxic France, Great Britain, plosives, and poisons from already exist, not only from wastes some 10,000 times Canada, hst Germany and other industries.) the nuclear power industry, greater than the entire Japan-are continuing with At reprocessing centers, but from the defense nuclear industry has pro- their repro:essing pro- . the spent fuel would be program.

duced since its beginning. grams. Urt .ium and pluto- chemically dissolved to nium will c:ntinue to be separate valuable unused The unfair burden The source recycled w:rldwide with or uranium and plutonium. .

without Ar erican The residual radioactive An unfair burden will fall As noted earlier, high- participatic.. wastes would then be solidi- on the shoulders of future level radioactive wastes are fied and blended into stable, generations only if we fail contained in the spent fuel non-dissolvable ceramic or to reprocess these wastes, Decision is due recycle usable uranium and from nuclear reactors. El ass materials, To maintain efficient '

A go ahead on reproc- In this form, the waste plutonium, and establish reactor operations, the fuel essing faci;nies by our would be scaled into federal burial sites for the must be periodically federal gos :rnment must ceramic or metal cannisters residual nuclear wastes.

replaced. Each of the two come soon:r or later. The and buried in dry, geo- The utility industry's reactors at our Perry I nation's breeder reactor logically stable areas such position on waste manag'e-Nuclear Power Plant, for program rr..st have a re- as thick salt beds thousands ment was put forth by the example, will have some processing facility and the of feet beneath the earth's Edison Electric Institute in 46,000 fuel rods containing I defense prc; ram is running surface. 1981. The statement said, the uranium pellets that  ! short on pL:enium. Mean- m part:

undergo a fissioning process while, sper/. fuel continues After burial "It is imperative that a to create heat. to be storec at the nation's federal policy and legisla-Once every 12 to 18 ' nuclear po-cr plants that Within 300 to 700 years, tion be set forth which months, one third of these could be used to fill these the radioactivity level of would initiate a program rods will be replaced with needs and a.so add recycled this waste would decay to and establish repositories fresh fuel. The spent fuel fuel to the ation's conven- the level at which it stood for the disposal of nuclear will be kept in a storage tional nucl:1r reactors. when the original uranium waste . . .

pool for several months P Once a p: scal decision was first mined from the " Completed reports by until it becomes consider- has been r .ide, the waste earth. It would continue to both the National Academy ably less radioactive. managemer: programs of decay below the radio- of Sciences and the Inter-the nation's ,uclear power activity level of natural national Nuclear Fuel Cycle Plans derailed industry ci move ahead, uranium, thus cleansing the Evaluation have concluded Congress is now making earth of some ofits natural that radioactive waste Originally, the plan for substantial :rocress in radioactivity. disposal can be carried out Perry and for other nuclear developing egIstative Salt beds and other geo- without undue risk to man power plants was to then

, guidelines. logically stable formations or the environment. But ship the spent fuel to a are ideal repositories for until a waste management reprocessmg center. Safe shipment high level nuclear wastes. facility is permitted to Here, unused uram.um Geologists estimate that operate, even on a demon-and the plutonium that is Spent fue. assemblies will even if ground water were stration scale, the public produced during the then be shg:ed to re- diverted into such areas, it will continue to perceive fissioning process would be processing :. ants in lead would take 50.000 years to that no solution exists to recovered. Both could be and steel cuo specially dissolve the surrounding the waste management recycled into new reactor designed are tested to with- salt or rock formations and problem." E fuel. stand JO-fo:: falls,80 mile- another 10.000 years to But in 1977, the Carter an-hour tri:Oc accidents. erode the waste containers.

Administration froze re- exposure :c re. and By then the radioactivity in processing plans for an 'immerstor: c w ater without the wastes would have long indefinite period. The any leakage- since decayed into harmless reason cited was that the (To date. . ore than 4.000 levels.

spent feel usemblies have been transp:rted in this country w = no one ever 5

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nTTACMENT 3 of what ctn be accomplished by a stead" and consistent commitment to importani Hypothalamic hormones and cancer scientific goals." The " steady and consist-ent" part, many U.S. space scientists feel, The hypothalamus was found during the doses of superactive LiiRH analogues to has been a sorelylacking aspect of the U.S. late 1960s and early 1970s to be the brain six patients with localized prostate cancer planetary program, whose progress is and body's executive hormonal switch- and to four patients whose prostate can-

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sometimes perceived as a succession of board, Roger C.L. Guillemin of the Salk In- cer had already metastasized. The pa-individual battles for separate funding stitute in Lajolla, Calif., and Andrew V, tients agreed to this experimental treat-needs. Calling attention to the declining Schally of the Veterans Administration ment since estrogen,a treatment for local role of the U.S. in planetary research, he liospital in New Orleans shared a N"obel prostate cancer that cannot be surgically said,"l know that we alllook f orward to the Prize for the discovery (SN: 10/22/77, p. treated and for metastasized prostate advances in human knowledge that soon 260). Since then the isolation, sequencing cancer, had not helped one of them and will be appearing in Soviet scientihc jour- and synthesis of hypothalamic hormones was contraindicated for the rest of them nals.

• The Venera accomplishment, he and the design of analogues of, and an- because of their medical histories. (Cas-said, suggesting a strong reference to con- tagonists to, them has opened a radically tration is another treatment for metasta-cerns abont the potentiallo.wes d the U.S. new approach Io hirth control, wdh one sired prostate cancer.)

loses its position ol space leadership,"has analogue ultimately reaching clinical The trealments brought about tumor surely aroused the admiration of people trials (SN: S/24/80, p. 331). And now regression and clinical improvement -

all over the world." His words were spoken hypothalamic hormone analogues look as such as beiter urinary flow and a decrease to Barsukov and Surkov. fins message was if they can counter some hormone. in bone pain due to cancer metastasis-in for Washington. sensitive cancers - notably hormone- nine out of 10 patients.(The tenth patient's Other planetologists feet, however, that sensitive prostate cancer - Schally and cancer was found to be hormone insensi-individual contacts rather than formal his colleagues report in the March Pao- "tive.) Schally and his colleagues conclude, agreements still provide the bulk of their CEEolNcs or T!iE NAllONAL ACADEMY OF .Long term administration of LHRH scientific exchange, and such one to-one SCIEN CEs. analogues could become an alternative to links are likely to continue."I could not see Luteinizing hormone releasing hor- surgical castration and estrogen therapy a situation," says the State Department mone (LHRH)is a hypothalamic hormone for the treatment of hormone dependent source,"where t he U.S. government would that controls sex hormones in both men prostate cc :inoma."

and women (SN: 8/12/72, p.108). Superac- liowever, the analogues were not with-try to restrict personal contacts."

-1 Eberhart live LHRll analogues (compounds similar out some undesirable side effects of their in structure to LilRH) increase levels of own, notably a decrease in fibido and erec-the male hermone testosterone, stimulate tile potency And as Avery Sanberg,a pros-Rad damage of polymem the testes, stimuiate hbido and influence late cancer scientist at Roswell Park other sex hormone related lunctions. Par- Memorial lnstitute in Buffalo, told SCtENCE At the bottom of a water-filled, stain. adoxically, however, large doses of these NEhs, what Schally and his group are do-less-steel lined pit, various construction analogues do just Ihe opposite. So Schally ing, essentially,"is changing the hormonal materials used in nuclear power plant and his co-workers tried to learn whether milieu. But it remains to be seen whether buildings recently were exposed to a such doses might make testosterone de. that effect is any better than w hat therapy cobalt-60 radiation source. The experi- pendent prostate cancer regress in ani- in the past has given. .Nobody has ever ments - conducted by Ken Gillen and mals. They lound that it does. cured prostate cancer with hormonal Then they attempted to see whether therapy." William Scott of the Johns Hop-Roger Clough of Sandia National Labora.

toriesin A:buquerque,N.M.-indicate that such doses can do the same for testoster. kins Medical Institutions agree "I think long term, low leveldoses of gamma radi- one dependent prostate cancer in hu- we have gone about as far as one can go ation degrade the materials laster than do mans,which constitutes about a half of all with hormonal therapy. I think any other equal doses doled out at a higher rate over cases of human prostate cancer. Over pe- hormonal manipulation is just a variation

-j A Treichel a shorter penod of time. riods of six weeks to a year they gave large on the theme."

The findmgs have implications for de-termining the lifetime of certain polymers Measles eradication as world-wide goal used in nuclear reactor structures. Tra.

ditionally, age testing of these materials has emphasized total radiation dose-not Although still regarded in some coun- gram. Currently, more than 96 percent of dose rate. A typical age test, for example, tries as just part of growing up, measles children entering school have proof of involves exposiap polymers to 40 Mega- infections take a heavy world toll. Each immunity. The annual incidence of rads-a radiation dose about equal to that year 1.5 million children die of the disease measles here has dropped from 336.3 expected dunng a plant's 40 year design and its complications, which include cases per 100.000 population in the 1950s life-over a period of several days. pneumonia and brain inflammation. The (before the vaccine came into use in 1963)

The Sandia tests, on the other hand,in. incidence of complications and death is to 1.3 cases per 100,000 population in 19S1.

volved administering lower doses over a highest in developing countries where So far in 19S2, a record low of only 130 longer period of time to more closely there is malnutrition and high risk of con- cases has been reported, says Alan R.

simulate the nuclear power plant envi- cur rent infections. ' limman of the U.S. Centers for Disease rnnment In one test, polyvinylchloride- At a meeting in Washington, physicians Control. He and colleagues predict in the which is used for cable jacketing - was from 21 countries concluded that world- March l9 Jot RNAt or Tite AMEniCAN Mto-shown to degrade three to four times wide eradication of measles is possible. ICAt. AssoCI ATION that by October 1982 faster at the lower level, longer term dose probably within 20 years An ef fcctive vac- indigenous measles will have been elimi-rate. Similar results were observed using cme is available, but major challenges are nated in the United States, although ap-polyethylene,a cable inst.lation material. expected in hnancmg immunization pro- proximately 500 cases per year will occur The Sandia tests show that polymer grams in developmg countries and in due to importation of measles with occa-damage, mostly embrittlement, occurs motivatmg some of the developed coun- sional, limited transmission. Other coun-when radiation exposure causes chemical tries, such as France and the Umted King- trNs making progress toward extensive it imunization of children include Canada, bonds to break, w hich in turn leads to oxi- dom,to participate.

dation -the combination of a substance The United States is cited as the best China. Czechoslovakia, Costa Rica, Cuba O example of a measles eradication pro- and Chile. O with oxwen

o-r CERTIFICATE OF SERVICE This is to certify that copies of the foregoing'.OEIOr 95"~ a j F' CITIZENS FOR RESPONSIBLE ENERGY MOTION FCR LEAVE TO FfLE'" h,,l ITS CONTENTIONS 17, 18, AND 19 were served by deposit in the /krf-U.S. Mail, first class, postage prepaid, this 22nd day of '

April, 1982 to those on the Service List below.

Susan L. Hiatt SERVICE LIST Peter B. Bloch, Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Frederick J. Shon Atomic Safety & Licensing Boa.rd U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 James Thessin . , Esq.

Office of the Executive 1 Legal Director U.S. Nuclear Regulatory Comm'n Jay Silberg, Esq.

1800.M Street, N.W.

Washington, D.C. 20036 Daniel D. Wilt, Esq.

7301 Chippewa Rd.

Brecksville, OH 44141 Atomic Safety and Licensing appeal Board Fanel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

.