ML20053B881
| ML20053B881 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/24/1982 |
| From: | Christamaria BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | |
| Shared Package | |
| ML20053B863 | List: |
| References | |
| NUDOCS 8206010312 | |
| Download: ML20053B881 (3) | |
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O'Neill Cont 3nt.ica 11 D The Licensee has not adequately provide for the protection of the public against the increased release of radioactivity from the expanded fuel pool as a result of the breach of the containment due to the crash of a B-52 bomber.
The root of this contention is that an increase in th
- spent fuel pool would present a higher fuelinventory that could be released due to a crash of a plane.
Although Big Rock was supposedly built to withstand a crash of a Being 404 no evidence has beer,;rovided by staff or NRC that this theory was actually tested.Unless actual testing is done of what the physical structure presently can withstand (including aging, j
s2ttling, embrittlement of building material) one can only assume it may withstand a crash of any plane...'..
At the time of construction nobody calculated that the facility would eventually hold such a larger amount of fuel at the facility for an expansion of the pool was not included in the original license L.c nor planning, of it.
i, Staff and licensee's major defense for this contention is the establishment of air corridors and PRA"a.
It appears from testimony that it m_ay be possible to enforce an aircorridor for the B52 and to have some control over the Air guards, however no such control exists over the private or commercial sector of aviation. Thai. concern was adressed under the SEP Assessment 4/14/80, where licensee meets the standard of Risk assessment of one in a million.T he SEP however neglects to adress that there is another aiport within 40 miles north of Big Rock that has major traffic of larger planes fbm Chicago or Detroit...
admittedly somewhat out of a direct aircorridor of Big Rock's vicinity, however close enough to maybe detour for sightseeing or disorientation due to bad weather.
It is my understanding that the Bay ShGre site was chosen as a site not for it's easy flying approach but for the hazards of learning to attack under very severe and unusual weatherconditions, since I hue no access to that information I have to rely on that from the experience of living here and what seems to be common V.owledge in tow 1....
Research of Riskassessment is fragmented, neither licensee nor staff has made computeri-sation of a Risk assessment of absolutely all aircrafts, one in a million and one in a million add up to at least 2 in a million ( PRA about the B-52 and SEP PRA) etc. etc......
No testimony has been provided to adress at all what would happen should 'an impact of any type of plane occur that has the potential to create havoc with systems outsideof the reenforced containment structe ret close to the control room maybe damaging vital electrical connections or systems that are needed to bring the plant under control so that no potential could exist for a scenerdo that could cause steamexolosions that also hava the potential to breach containmeny.
6 L #" $ C As the board rightfully noticeda environmental shielding q give better protection.
Licensee and staff should prove to.us that either they have a facility that can take the icpact of a_n2 type of plane withput hazard to the public or the environment or establish i
a fcolproof controlsystem that avoids any plane within a scientifically established safe aircorridor.As previously stated licensee has only partial control over that......
An expansion si the fuelpool should not be permitted for it allows a higher fuelinventory to be released, not until licensee can improve the facility to be "crashproof" or control l
.is established to keep away all planes'.
l Randing the newspaperclippings from 1971 that dealt with the B-52 crash close to the vicinity nobody would have believed that this was the one in a million crash of the PRA's, at that time people did want to know what could happen to them in case the plane
.would have crashed on Big Rock, that fear was very real to a lot of people in the i
community and the concern remains.
Can licerfsee or NRC protect us from a terrorist or deranged person that decided to buzz Big Reck li%e May 4, 80 for the fun of it or some Kamikaze oriented person?
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A crashproof facility is the only solution to lay the concern of this contention to rest not some syb ijute to minimize it.
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C Christa-Maria t:stinn3 tol Centsnticn 9 The cunent emergency plan is based on reactorinventory and breach of containment, or spent fuel pool and breach of containment, but does not take into account the
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possibility of combined reactor inventory and spent fuel pool and breach of containment.
Any change in the spent fuel pool should require a resultant change in the emergency l
plan.
D A total fuelinventory is not even included in current planning and that the existent l
planning leaves doubt to fulfill it's achievements licensee should prove that it i
etn safely plan for an emergency with an increased fuelinventory.
Presently licensee or the county has ill prepared the community on education to understand a radiological emergency accept that they are to follow like blint/ sheep j
and that is radiation is as harmful as the sun or a planeride to Denver......
tiothing has been done to consider the more disasterous effects of breach of containment l
by plane or steamexplosion that for instance would hurt more workers that have currently been used in statistices for drills ac.gic.a Big Rock has so many license amendments and manual to employ to enforce them, that I do not find in any emergencypreparations a scenario that adresses what would happen with a skeleton crew that has to bring the facility under control for a LPss of offsite I
powe ^ situation regarding the spent fuel pool should containment entry not be possible, a
how many hands woule it take at Big Rock to alone bring a LOCA under control how many more would it take to handle th-continuance.of proper cooling to the pool?
What amounts would have to be relrased into the atmosphere to make working conditions safe, is the county prepared Tor that?Is the manpower and equipment prepared to handle that? it does't seem likely for it is already spav a, Big Rock because of it's H0X fuel does have a good amount c} P u'fn'kot already prese l
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fuelinventory no licensamendment should be given that increases the potential for a larger fuelinventory until cuarent planning that adresses, an unexpanded pool has met all regulated criteria including TMI deferred and ar.fec;drJ, issues.
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m Ate.ic Safety and Licensing JerspF Calle, Enquire E ard Panel Ishe, Linen]n and Beale 3
U.S. Nu: lear Regulatory 1110 Cor.necticutt' Ave, N.W.
Conn ssien Suisc 325 Washingte...
D.C.
20555 Washington, D.C.
20036
. Esq., Chairman Peter B..Bloch, Atomic Safety and Licensing y.
I Board Panel
, ify U.S. Nuclear Regulatory l
Commission
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Washington D.C.
20555
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Dr. Oscar H. Paris l
i Atomic Safety and Licensing
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Board Panel U*S* Nuclear Regulatory Docketing and Service Section Commission of fice of the Secretary Washington D.C.
20555 U.S.
Nuclear Regulatory Commis sion Mr. Fredrick J. Shon Washingten, D.C.
20555 Atomic Safety and Licensing John.O'Neill, II Board Panel Reute 2, Box 44 U.S. Nuclear Regulatory Haple City, MI 49664 Commission Washington D.C.
20555 Richard Goddqtd Sta,.;
Counsel for Nn-
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U.S. Nuclea r Re gulatory Contis sion Washincton, D.C.
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