ML20054B670
| ML20054B670 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/13/1982 |
| From: | Semmel H ANTIOCH SCHOOL OF LAW, WASHINGTON, DC, BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20054B665 | List: |
| References | |
| ISSNAUCES-OLA, NUDOCS 8204190045 | |
| Download: ML20054B670 (4) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
)
Docket No. 50-155-OLA
)(Spent Fuel Pool Modification)
CONSUMERS POWER COMPANY
)
)
(Big Rock Point Nuclear Power Plant)
INTERVEN0RS SUPPLEMENTAL RESPONSE CONCERNING CHRISTA-MARI A CONTENTION 9 In response to the request of the Licensing Board, Intervenors submit supplemental information concerning the bases for contention 9.
Intervenors expressly reserve their position that Contention 9 is al-ready admitted in the proceeding and the only proper method for re-moving it is through the summary disposition process in which licensee, not Intervenors, have the burden of demonstrating there is no material issue of fact to be heard.
i Problems With the Emergency Plan In General Will be Exacerbat'ed By Increased Storage In The Spent Fuel Pool.
Overall weakness in the emergency plan such as monitoring communica tions, personnel and evacuation times will be subject to further stress in the event the spent fuel pool is expanded.
8204190045 820413 PDR ADOCK 05000155 G
- o As Intervenors stated in the previously submitted "Specifica-tions", current monitoring is done in some instances by extrapolation.
(Specifications p. 3).
Ex tra pol otion is a time consuming process that is not suf ficient to serve emergency needs when combined with deficient equipment.
In the event of a spent fuel pool expansion, radiation will be released at faster rates and higher levels than is currently antici-pated with regard to breach of containment.
Time delays and monitoring inaccuracies will become critical in such a situation.
Accurate and quick measurement is of the essence in order to offer adequate pro-tection to children and pregnant women whose sensitivity to radiation is much greater than that of the general public.
Current evacuation times are inadequate to preserve health and sa fe ty. Given the increased quantity and faster release of radiation that would occur with a spent fuel pool expansion, the evacuation times will not meet the exposure requirement under 10 CFR 100.ll(a)(1),
i The current plan does not meet the exposure standard under 10 CFR 100.11 (a)(1) in the fact that evacuation isibpossible in much of the winter.
In light of the increased probability of criticality that would occur with an expansion of the spent fuel pool as raised in John O'Neill Contention II E3, the need to correct any weakness in the current emergency plan becomes imperative.
Any such weakness could become a problem of a critical nature in light of the increased radiation and faster rates of exposure to the general public that would occur with expansion.
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Breach of containment with an expanded pool would allow a higher fuel inventory to escape and therefore endanger the public in ways emergency planning is currently inadequate to handle.
"The increased quantity of plutonium in the Big Rock Point core introduces the possibility that core nuetronics are afflicted infavorably or that the increased toxicity of plutonium results in an unacceptable increase in radiation doses to the pulbic during normal or post accident conditions."
U.S. Atomic Energy Commission Docket No. 50-155 December 6, 1972, Memo of James Shea, p.4.
Licensee states that no M0X fuel will be processed on site and that Licensee has exhausted its supply of M0X fuel.
However, licensee does not state that no new M0X Fuel will be added to the spent fuel pool.
Furthermore neither Intervenors nor the Board are bound to blindly accept the statements that no M0X fuel will be processed on site and that no plutonium will be recycled on site.
This may be Licensees current plan, which is, of course, subject to change.
l The current emergency plan is based on reactorinventory and breach of containment, or spent fuel pohl and breach of containment, but does not take into account the 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 plan.
Resppetful,1y submitted, i
y LoL/
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On the Memorandum:
Herbert emmel Attorney for Intervenors Denise Wiktor Christa-Maria, Mills and Bier Antioch School of Law t o h School of Law 2633 16th Street, N.W.
Washington, D.C.
20009 (202) 265-9500 ext. 240
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i CERTIFICATE OF SERVICE I certify that copies of the foregoing Intervenors Supplemental Response Concerning Christa-Maria Contention 9 were served on the attached list on the 13 day of April 1982 by delivery to the office listed thereon or by U.S. mail, first class postage prepaid.
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