ML20054D978

Motion for Admission of New Contentions Re Accelerated Wear on Steam Generator Tubes & Financial Problems.Certificate of Svc Encl

ML20054D978
Person / Time
Site:	Summer
Issue date:	04/14/1982
From:	Bursey B BURSEY, B.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8204230561
Download: ML20054D978 (6)

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'e .- ATOMIC SAFETY & LICENSING BOARD )'

In- the Matter of: )- _ . _

) i South Carolina Electric & )

i Gas Company,'et. al. ) ~ Docket No. 50-395-ol

) April 14, 1982 'O [g, 20 0'>

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(Virgil C. Summer Nuclear )

• B Station, Unit 1) )

MOTION FOR AD*11SSION OF NEW CONTENTI NS

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- MOTION FOR ADMISSION OF NEW CONTENTIpNS h ['

1 g'sp As the Intervenor.in this proceeding, I her t?

new contentions, as set forth below, be admitted to t proceeding and that further hearings on these matters be held.

On March 10, 1982, I was informed by reports in the Columbia Record that the Applicants, South Carolina Electric & Gas Company and the South Carolina Public Service Authority, were -

admitting that because of a design defect in the steam generators ,.

at Summer they could not safely run the plant at more than half speed.

According to these stories, if the plant ran at more than 50% power, vibrations from water flow in the steam generators would cause the tubes to wear through in a very short time.

Although I received a Board Notificatiori about steam f i

generator concerns in January, after the hearings had ended, I was not informed that this wear problem was actually causing ,

leaks or that those leaks would appear so quickly. In fact, the attached memo from Duke Power's McGuire people suggested . ,

that they were not having wear problems at that point. In mid- D March I received a memo, dated March 12 or 13, which reported I6 on an NRC meeting with Westinghouse about steam generators. ,

i According_to that memo, this accelerated wear problem would appear in Model D3 steam generatos like those at Summer if.the i plant were run at more than 50% power.

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, 2 This raises significant safety questions which this Board should address before licensing the Summer facility.

Had I known how serious a problem this was before mid-March, I would have filed this motion sooner. As soon as I found out about it, I moved as quickly as I could given my current schedule. I think that I have good cause to file this motion 5 E

now and that it is timely. 2 D

I would move that the following contentions be admitted b I

and hearings on uhem held: E E

New Contention 1:

Accelerated wear on the steam generator tubes at Summer k 5

t-threatens the health and safety of the public from an uncontrolled . f E

release of radiation to the environment. Failure of a PORV

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valve, like happened at Ginna in January, can result in a  ;;

A safety valve on the steam generator opening a releasing radiation which will reach the environment. In a LOCA, weakened steam ~

5 generator tubes can rupture. Steam can leak from the steam E a

generators into the primary cooling loop. There steam binding E

can keep the ECCS from working properly and lead to a meltdown.

These, and many other accident scenarios, can lead to uncontrolled i releases to the environment.

If Summer is not safe to operate at full power,  :.. .

ik it should not be allowed to operate at half power. I:T3 p.

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New Contention 2:

The Applicants will be unable to raise the funds needed to safely operate Summer. South Carol,ina taxpayers are already so overburdened by the high rates to pay for Summer that SCE&G c.ut off 14% of its customers in 1980 because they couldn't pay their bills. Mark Whitaker, who is in charge of licensing Summer for the Applicants, has told the newspapers that he can't even tell the year when they'll be able to operate the plant at more than half speed. If this billion dollar plant can't be run at but half power, they are going to have to charge twice as much for each kilowatt to pay off their debts.

Rate payer rebellions on the Pacific coast and elsewhere have shown that rate payers won't stand for it anymore. Already in South Carolina, many poor people have to go without electricity because they can't afford SCE&G's rates. Many more will stop buying. SCE&G will have to raise its rates further. Pretty soon only the over-paid SCE&G executives who built this defective plant will be able to buy their electricity.

New Contention 3:

The NRC Staff's failure to calculate the benefits of Summer based on production at half-power operation and to include the certain costs of massive repairs and/or replacement of the defective steam generators is of sufficient weight as to shift the balance against the favorable cost-benefit balance struck at the Construction Permit stage.

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. 4 When the Staff struck its cost-benefit balance, it assumed that the plant would run at full power. But that balance should be restruck taking into account that the benefit is an unreliable 4 50 MW plant and not a 900 MW plant. In addition to the billion dollar plus construction costs, the additional millions of dollars for repairs or replacement of the steam generators should be added into the costs.

I know of no other party, since I am the only Intervenor, who can represent my interests. Surely the Applicants don't.

The Staf f doesn ' t. The State won't. The Board needs to get in the Westinghouse and Staff experts snd get to the bottom of this before they can say that the plant is safe to operate.

That may cause a slight delay, but I have moved as quickly as I can. I do note that the Applicants have again put off fuel load readiness. Waiting for fuel load readiness at Summer is getting to be like waiting for Godot.

There is already a financial qualifications contention before the Board. New Contention 2 really only makes that more particular and seeks more testimony from the Applicants and the Staff. The other contentions may open new ground, but they raise issues which are so serious that if they were not addressed equipment which presents a very real danger to the public would be allowed to operate.

The Applicants and the Staff will probably argue that

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the financial qualification issue should be addressed by the South Carolina Public Service Commission. Since paid agents of SCE&G - lawyer-legislators on retainer to SCI &G - control

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the election of members of the SCPSC, that is not a fair forum .

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for citizens. l I believe that I neet the recuirer.ents of 10 CFR 2.714 (a) and would ask that this motion be granted and that these new contentions be adnitted and hearings held on them.

Brett A. Bursey i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS:0N

-P?

l ATOMIC SAFETY A'iD LICENSING E0ARD 4

-In the Matter of: )

')

~ SOUTH CAROLINA ELECTRIC & )

GAS COMPANY, et -al. ) -Cccket No. 50-395-OL

)

(Virgil C. Summer Nuclear )

Station, Unit 1 )

t i.

CERTIFICATE OF SERVICE t I hereby certify that copies of Intervenor's " Motion for Adr.ission of New Contention" in the above-captioned proceeding nave been served On the following I by deposit.in the United States mail, first class, on this 15.h day of April j 1982:

Herbert Grossman, Esq. , Chairman Jose;7 B. Knotts , J r. , Esq.

' Administrative Judge Debevoise & Liberman Atomic Safety and Licensing Board 1200 17th Street,t.W.

U.S. Nuclear Regulatory Commission Washington, D.C. 20:36

Washington, D.C. 20555 Georce Fischer, Esc.

Dr. Frank F. Hooper Vice President & Grou: Executive Administrative Judge S.C. Electric & Gas C:.

School of Natural Resources P.O. Box 76 University of Michigan 48109 Colurcia, S.C. 292:3 Randolph Mahan, Esc.

1 Mr. Gustave A. Linenberger Administrative Judge Se C. Electric & Gas :o. +

l Atomic Safety and Licensing Board 100 5. Main Street U.S. Nuclear Regulatory Commission Colur.bia, S.C. 292C1 Washington, D.C. 20555 Chaitinan, Atomic Safe y and Licensing Board Chairman, Atomic Safety and Licensing Par.el l

Board Panel U.S. Nuclear Regulate y Commission

- U.S. Nuclear Regulatory Commission Washington, D.C. 2:555 Washington, D.C. 20555 Mr. Chase R. Stephens Richard P. Wilson, Esq. Docketing and Service Section

' Assistant Attorney General Office of the Secretary

-S.C. Attorney General's Office U.S. Nuclear Regulatcry Commission 1 Washington, D.C. 20555 P.O. Box 11549 L Columbia, S.C. 29211 Jahr C. Ruoff.

. Steven C. Goldberg, Esq. P.O. Box 95 l Office of the Executive Legal Jenkinsville, S.C. 2055 l

Director Robe rt Guild, Esq.

! U.S. Nuclear Regulatory Commission

! Washington, D.C. 20555 314 Fall Mall i Col t.-b i a , S . C. 292 01 '

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L -Brett Bursey,lIntervenor

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