ML20062G850
| ML20062G850 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/10/1982 |
| From: | Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8208130200 | |
| Download: ML20062G850 (20) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH-CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
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(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
APPLICANTS' RESPONSE TO AMENDMENTS
, (THIRD SET) TO CONTENTIONS OF PETITIONER WELLS EDDLEMAN At the Special Prehearing Conference held on July 13 and 14, 1982, petitioner Eddleman distributed to the Board and
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parties an undated and non-paginated document setting forth i
l additional proposed contentions and amendments to previously proposed contentions (the " Amendment").1/ (A copy of the l
l l 1/ Mr. Eddleman initially filed numerous proposed contentions on May 14, 1982. Subsequently, on June 5 and June 28, 1982, -
petitioner Eddleman filed certain amendments and additions to '
his original proposed contentions. Applicants have responded to all previously proposed contentions'and amendments thereto.
(Continued Next Page) l r2081302OO 820810 PDR ADOCK 05000400
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Amendment, with page numbers added, is attached.) In accord-ance with the agreements entered into during the Special Prehearing Conference (see Tr. 444-446), Applicants herein respond to petitioner Eddleman's additional contentions and amendments.
Initially, it should be noted that two of the issues Mr.
Eddleman seeks to raise in the third amendment to his proposed contentions have been explicitly subsumed by the consolidation agreement entered into by petitioners CHANGE, CCNC, Kudzu Alliance and Eddleman. In particular, Mr. Eddleman's proposed
." substitute on radiation health effects" (at pages 5 and 6 of the amendment) has been replaced by Joint Contention No. II.
Similarly, revised Eddleman' Contention 3D (at pages 7 and 8 of the Amendment) has been encompassed by Joint Contention No.
I.2/ Therefore, only the following amendments and/or additions arising solely from Mr. Eddleman's third amendment are before the Board for decision: revised Eddleman Contention 64X (spent fuel accidents); revisions to proposed Eddleman Contentions 1 (Continued)
See Applicants' Response to Amendments (Second Set) to Contentions of ?etitioner Wells Eddleman, dated July 13, 1982.
l 2/ In a telephone conference between Mr. Eddleman and i Mr. O'Neill, Mr. Eddleman agreed that these two amendments had been superceded by Joint Contentions I and II. See also Joint Contentions of Intervenors (July 13, 1982) at 1-4, 8 and Tr.
244-245, 354.
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and 29 (radiation monitoring); and, what appears to be a restatement of Contention 84 regarding the release of chemical
. pollutants or carcinogens from the Harris plant. Applicants' responses to these contentions are set forth below.
At page 1 of the Amendment, Mr. Eddleman proposes to amend his Contention 64 with the bald assertion that "the spent fuel building at Harris has not been shown to be fully tornado-missile resistant in its parts which abut the sites and ,
connections to cancelled units (e.g. 3 and 4)." The amended contention lacks a stated basis with reasonable specificity.
i In fact, the fuel handling building is a reinforced concrete Seismic Category I structure (FSAR 5 3.8.4.1.3) which is designed to withstand all loads and loading combinations set forth in FSAR S 3.8.4.3, including tornado missiles (FSAR 6 3 8.4.3.l(d)). See also FSAR S 3.5.
Mr. Eddleman then repeats his assertion, previously made both in Contention 64(c) and his "6/28/82 Amendment to Petition -
to Intervene", that storing additional spent fuel from Brunswick and Robinson at the Harris Plant increases both the danger of radioactive releases and the probability of a fuel 7
handling accident. The design basis for spent fuel storage l
l includes maximum storage of both PWR (Harris and Robinson) and
, BWR (Brunswick) spent fuel. FSAR S 9.1.2. The fuel pocl cooling system with redundant means of ensuring cooling water l
l is addressed at FSAR S 9.1.3. The Harris Plant fuel handling 1
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system is described at FSAR S 9.1.4. The fuel handling system is specifically designed to handle Robinson and Brunswick spent fuel. Accidents involving fuel handling have been analyzed in the ER at section 7.1.10, including an accident involving Brunswick (BWR) opent fuel. The results of such an accident are inconsequential. Mr. Eddleman has not challenged this analysis or the safety analysis in the FSAR. Thus, there is no basis for a contention that a safety or environmental issue, not adequately treated in the FSAR and ER, is involved in storing or handling the additional spent fuel.
Mr. Eddleman's proposed " substitute" for his initial Contention 1 appears, at first blush, to provide a wealth of specifics beyond those set forth in the original Contention 1.3/ However, Applicants submit that the proposed substitute continues to fail to meet the basis with requisite specificity requirements of 10 C.F.R. $ 2.714(b), as discussed below.
The thrust of proposed substitute Contention 1 appears to be three-fold: (1) the radiation monitoring system is inadequate in that it measures, for the most part, only gross gamma activity; (2) the power supplies for and environmental qualification of the radiation monitors is inadequate; and, (3) the radiation monitoring system microprocessors and computers 3/ Mr. Eddleman notes that this proposed substitute might also possibly be combined with his proposed Contention 2. See Amendment at 2.
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are unreliable and environmentally unqualified. With respect to the first issue, as noted in Applicants' Response to Eddleman (June 15, 1982) at 104-105,.Mr. Eddleman fails to provide any factual basis in support of his allegation that the radiation monitors must be capable of analyzing the specific radionuclides and concentrations being emitted. Absent a showing that such information is required to properly respond to an accident at the Harris Plant, Applicants contend that this portion of Contention 1 is inadmissible.
Mr. Eddleman is incorrect when he contends that the p.ost-LOCA monitors are capable of surviving for only 15 minutes in a LOCA environment. FSAR 5 12.3.4.1.8.1, cited by Mr.
Eddleman, describes the containment isolation monitors, not the post-LOCA monitors. These isolation monitors, located inside containment, have as their main function the initiation of damper isolation but may also be utilized to provide an alternate indication of post-LOCA activity. They are qualified to survive a post-LOCA environment for 15 minutes. The actual post-LOCA monitors, located outside of containment, are l
qualified to the criteria of IEEE Standard'323-1974 which requires the equipment to have a lifetime of 40 years, with l
survivability for one year in an accident environment. See FSAR 5 12.3.4.1.8.2. As noted in FSAR S 11.5.2.5.1, the GM tube detectors used for the post-LOCA monitors are qualified to the following parameters: 131 F temperature; 100% humidity; -
and, 10 rads integrated dose.
Mr. Eddleman also takes issue with the independence of the j i
power supplies for the radiation monitors, asserting that there 1 I
is no proof of the independence of the supplies. FSAR )
$ 11.5.2.1.2 states that the redundant safety-related monitors are powered from the station 120V AC safety-related buses, while the non-safety-related monitors are supplied from the station regulated 120V AC instrumentation bus. Mr. Eddleman, however, does not provide any basis for his allegation that these particular power supplies are insufficient. Similarly, Mr. Eddleman appears to assert that the check sources used for the monitors may be inadequate.4/ This proposition, however, is unsupported by any factual basis. Further, to the extent that Mr. Eddleman's concern here relates to the effect of decay on the check sources, the calibration procedures described in FSAR $ 11.5.2.4.4 will provide assurance of the accuracy of the check sources.
Mr. Eddleman, at pages 2 and 3 of the Amendment, sets -
forth a series of postulated inadequacies in the microproces-sors and computer systems for the radiation monitoring system in support of his allegation that these systems are not properly qualified. Mr. Eddleman, however, fails to address 4/ Mr. Eddleman is incorrect when he states that the check source half lives "may be as short as 7 years". Rather, all check sources have half lives greater than 7 years. FSAR S 11.5.2.4.4.
-the relevant FSAR sections. See FSAR 5 11.5.2.3.1 (the safety-related portion of the system meets the criteria.of IEEE Standards 279-1971, 308-1974, 323-1974, 336-1971, 334-1975 and 384-1974) and 5 11.5.2.4.5 (microprocessors are designed to operate at 32* to 131 F, O to 95% humidity and for an inte-grated lifetime radiation dose of 1000 rads). Such broad-brush, generalized allegations which fail to take issue with the information available do not meet the bases with requisite specificity requirements of 10 C.F.R. 5 2.714(b).
The last paragraph of proposed substitute Contention 1 claims that the TMI Appendix to the FSAR (pre-Amendment 3) does not contain sufficient information regarding the radiation monitoring equipment needed to comply with the TMI Action Plan.
Amendment at 4. Amendment 3 to the FSAR has consolidated all of the information regarding the post-TM1 radiation monitoring requirements,into the general description of the Harris Plant radiation monitoring systems in section 11.5. Further, additional details regarding the type and operation of the radiation monitoring equipment required by the Action Plan has '
been provided. See, e.g., FSAR 5 11.5.2.5.11 (Wide Range Noble Gas Monitor) and 5 11.5.2.7.2.17 (High Range Containment Monitors). Therefore, this portion of proposed substitute Contention 1 is moot and should be withdrawn by Mr. Eddleman.
At page 4 of the Amendment, Mr. Eddleman offers what appears to be an amendment to proposed Contention 29, to which
l Applicants have previously objected. See Applicants' Response to Eddleman (June 15, 1982) at 109. Mr. Eddleman claims that Applicants have only " makeshift procedures" for performing .
1 radiciodine analyses, citing page 68 of the TMI Appendix to the FSAR,5/ and raises a number of questions with regard to the procedures for performing such analyses and the qualifications of the personnel performing the analyses.
As described at page 61 of the TMI Appendix to the FSAR (Amend. 3), Applicants' procedures for performing both portable and stationary monitoring of radiciodine concentration will~
meet the criteria of NUREG-0737, Item III.D.3.3. Mr. Eddleman has not asserted that Applicants' procedures are not in accord with these criteria.6/ Indeed, Mr. Eddleman does not raise a single alleged deficiency which could be viewed as a litigable issue -- rather, Mr. Eddleman merely postulates a number of questions which he believes should be answered in the FSAR.7/
, 5/ Due to the recent amendment to the FSAR, this same infor-mation is now found at page 61 of the TMI Appendix, as Appli-cants' response to Item III.D.3.3 of NUREG-0737, with addi-tional information regarding radioiodine analysis capability found in 9 11.5 of the FSAR.
6/ Mr. Eddleman does characterize the use of a single channel analyzer for portable monitoring as " makeshift"; this type of analyzer is, however, recommended by the Staff for portable monitoring. See NUREG-0737 at III.D.3.3-1,2.
7/ Certain of the questions raised by Mr. Eddleman are answered in'other sections of the FSAR. See, e.g., FSAR S 12.5 (qualification of Health Physics personnel, Health Physics instrumentation and procedures); 9 9.4.3 (ventilation design -
for Waste Processing Building); 5 11.5.2 (in-containment (Continued Next Page)
Absent a showing that such information must be provided in one place in the FSAR or that Applicants' plans for monitoring and analyzing radioiodine concentrations are inadequate, Applicants submit that the amendment to proposed Contention 29 must be rejected as failing to meet the requirements of 10 C.F.R. 5 2.714(b).
At pages 9 and 10 of the Amendment, Mr. Eddleman proposes a restatement of Contention 84 dealing with the discharge of
, chemicals into the Harris Plant cooling lake and the alleged impact of the interaction of these chemicals with other compounds present in the local water supply. This restatement of Contention 84 does not, however, provide any further support u for Mr. Eddleman's earlier allegations. Additionally, Mr.
Eddleman continues to fail to address the information available to him which presents specific analyses of the subjects raised by Contentions 84 and 85. See Applicants' Response to Eddleman (June 15, 1982) at 48-50. For the reasons stated therein, -
Applicants maintain that Contention 84, in either its original form or as restated, should be rejected as lacking the basis with requisite specificity required by 10 C.F.R. 5 2.714(b).
(Continued) radioiodine concentrations are continuously indicated in the control room). The actual detailed procedures for conducting radioiodine analyses would be contained in individual Health Physics procedures.
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t For all of the above reasons, Applicants object to the admission of all amendments proffered by Mr. Eddleman in his supplement of July 13, 1982.
Respectfully submitted, V ,
George F. Trowbridg'e , P.C.
Thomas A. Baxter, P.C.
John H. O'Neill, Jr.
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North Carolina (919) 836-7707 Counsel for Applicants DATED: August 10, 1982 N
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R'cv. Eddisman 614X The spent fuel building at Harris nas not been shown to be fully to;nade-missile resistant in its parts which abut ,
the sites and connections to cancelled units (e.g. 3 and L).
By storing additional spent fuel (high level radioactive waste) from Brunswick and Robinson at the site, CP&L is raising the danger of radioactive releases from this building, since that increases the anount of spent fuel present over what would _
be allowed were Harris not licensed to receizve snent fuel.
The transshipment of s) ent fuel fron other reactors to storage Harris for temporary ==*wegn means that all such fuel will will' be handled twice a t Harris while radioactive (irradiated).
This increases the probability of a fuel handling accident at
, Harris, either in receiving spent fuel, or in loading it to go
( to its final resting place or yet another intermediate storage, fx G$gl hwy $ '! Qh AB 4 G'/1l5' Y'3k' 'C'l e:RE6; 34 A ana g a i taan w.,oh -~ m a+e pj g @ jt'd B I
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,4p;79f:,;,g substitute for Eddleman #1 /
j;ap g9, 3 d f 05S lh C#Abf A/4 Wf EM.1 The radiation Monitoring sy sten of SEEPP is unable to provide tinely and sufficiently accurate notification of radiat6cn releases to inforn emergency resnonse eersonnel' because (1) the see e.g. Table 12 3.4-1 pp 12 3.k-9 thru-23, ref PSAR 11.5 monitors measure mostly gamma, not other radiation, and cannot identify =th-wtix specific isotope s being released (FSAR 12 314.1.k3)
(2) the post-LOCA monitors can only survive 15 minuxxtes nost-LOCA per FSAR 12. 3 4 1.8.1 (containment nonitors ), see 12.3.h.1.8.2 (3) the airborne radiation monitors and others neasure ma".nly gross activity (FSAR 12 3.h.211(e) even though they serve to detect activity in the buildings (section (a) of the above) which may leak out, and to detect leaks (section (d) of above), and to
/ evaluate the function of minimizing radiation release to the t
accessible areas of the plant and to the environment (section (f))
as 23 18 Hall well as (g) xim initiating isolation in an emergency.
The indenendence of the power supnlies (for the monitors) is not ,
established by FSAR 11.5 which nerely asserts they are indenendent.
Indeed, the Unit 1 backup nay be " Unit E" which no longer exists.
The chech-source halflives may be as short a s 7 years (11.5.2.h.h )
and thus will change their output by a f actor of 16 over a 28-year plant operating life.
The Process & Effizuent Radiological Monitor'ng systems (115.2.1.1 and 11.5.2 3) depend on microprocessors and conputer equipment not qualified for accident conditions ,aor at least not assured to be same, see the vague lanEuage of FSAR 11.5.2.2 -
Further, tnere is no direct indication in FSAR 11.5 or 12.3 4 4
that the microppocessors have a reliability sufficient that they will not err if, e.g. , contaninated by moisture ( a likely
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oscurrrnco in ths humid cros .of SIDPP, compara the large number of instrument LERs at Brunswick caused at least in part by noisture
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in instrumentsa or in/on wiring. Nor is the wiring shown b- the FSAk to be reliabile to accurately transnit readings at all tines.
Finally, t,he information is processed throu6h a d edicat e d microprocessor (11.5.2.1.1) with no backup state 6' or described, yet and interrogated and used by yesi an other comnuter ("the annronriste radiation monitorinE system computer") before it can be displayed on CRT's, alarmed, or the data stored or produced as hard copy.
It is well known that co .puters have sof tware errors, hardware failures, I/O mismatch problens, etc., but the FSAR does not explain how the vital radiation level information (which wS 11
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be, incomplete because of incor:plete monitoring systems concentrating s
3, mostly en gar:ma, mostly being just counters) v.11 always be d
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s accessible to energency response personnel both on and off-site, minimized or or how these computer problens will be avoided, and dealth with when they do occur, an some inevitably will, error-free connuters being rarer than error-free humans (the ones who design, bhild, install and operate computers). The PSA9 does not explain how
, the data fron radiation nonitoring is stored in the conouters l
(of if) and how the conputer data storage protects the data agains t accidental erasure or accidental shut-off of availability by hardware failures, I/O errors, sof tware bugs, or onerator error.
The mechanisns and software and hardware involved are not i
described in sufficient detail to allow analysis of the above problems at this tine, nor is any test data on the n.'eroprocessors, sof tware, and other cor.puter ecuiement involved (per FSA5 11. 5. 2.1.1 e tc )
4 given in the FSAR, either on SENP?'s equipnent or co7rable ecuimment or identical equiument elsewhere. fj \(' $ ? ? -CQy cs g {! % ,J O d ' -
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CDovwk W5 ai 6 is (H M tb CW/. (i210 S Gh2N.; CQuH,rh W;d*
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l ; 63 FSAR TMI-1 app:ndix at 59-ka does not identify the n:nitors to ba instellod, nor the sof twara and hardwara nodifientiona l
to be made, to conply (dhis is before Anendnent 3, which was just put into the Raleigh LPDR July 2 '82 and which I have not nad time to make a cocy o f) with T:!I action plan requirements . The statement s are so vague (e.g. CP&L will continue to review, in see IY, at p. TMI-63, "are described in see IV" (p/59) where section IV does not describe them, nor de the table TffI 2.1.8.b.3 descriptions giv~e nore than roughj and unverified parameters for the monitors for releases.
Such info is inadqquate to assure that tinely informat on f
will be available for emer6ency response eersonnel on the release levels which may threaten the oublic health and safety R,w+3 d in an accident.
Per Eddleman #29, radiciodines. "Page TMI-68 of the FSAR, pre-revision 3, does not tell how fast radiciodine analysis can be done, but describes makeshif t precedures, e.g. using a single channel analymazzer" capable of being calibrated to the 364-365 kev ener5y of Iodine-131"(how long does this take? Is there always a qua1.ified person near the cart-mounted sampler to do it? Are there enough spare sampling cartridges? The "cA9 nee -andt 3 doesn't savl, analyzine in SH PP's own counting lab (which may be" hot" with radiation due to primary coolant senples, etc. ), but again involving a procedure (purging in a controlled sanple ares, followed by dextz dessication using an oven-vacuum system) which doesn't tell how long this procedure takes, how many neonle are needed to do itk, how the countin lab's clean air suoply is assured, and how soon the results weuld be available to emergency resconse personnel under adverse conditions.
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, substitute on radintinn health effects (for Eddleman Applicants' and NRC Staff's analysis of the health effects of radioactive emissions: J SHUPP operations and accidents, '
A. From thanxnzhxnxn>s2xbxnytcho, falls to take account of evidence, e.g. as develooed by K.7.. Morgan (Bull At Sci. Sent '79?),
J. Rotblat (ibid), John Gofman (Raidiat$ on and Hunan Health,1981; see also Jean L. Marx article quoting h3 u, Science, !!/79), Mandcusn-Stewart-Kneale (Health Physics (1979) and other~ articles; see also Gorman review of tidir work, Health Physics );
Charlea '.l. Huver, Ph.D.-- Hinnesota study for LEAF, 3368 Oak Ave, Stevens point, 'clI -- especially strong on e.'fects o* twitium, for which see also uork of K.z. Morgan -- tritium a najor effluent of PWRs like Harris (Morgan, personul communicat t.on to U.S. , 6 82));
Dixon, Jacobson, and Dixon (John Gofman, consultant) Wisconsin study of n-power and n-weancns wastes effluents and dose commitments therefrom (Methodologies for the Study of Low-Level Radiation) docunenting increased risk fron many cancers due to nuclear plant '
i enissions (Set' ICRF, Box 967, Ardsley, NY 10$02, Frogs in Hot Water,
& J.T. Edra11, e.g. Bull At Sci' 9/76!
(1981) at p.15), the work of. c.nr1 Johnson, ton plutonium toxicity (ref. National Cancer Institute, 3d national Cancer Survey), Gordon MacLeod (State of Pa. Dept of h;ealth Dept. ), B.L. Molholt, Tr.heshi f Seo (ref 6/28/82 amendament), L. van Middicswcrth (ibid),
the work of Bross, Berte11, Sternglass et al on damage to immune systems and bodily defense against other diseases (and greater ,
j risk fron radiation and radionuclides to certain grouns in the t
- i. population, e .g. Ulose with asthma , all er6 0s , e tc ) . Feirst ens 4
l ' 4 .u. w .:! w ly j from the, plant are not adequatsly p estimated, nor are sufficiently cccurate detectors (e.g. pressurized ionization) nrovided to
identify the nuclides emitted and the amount of each emitted.
Thus, cancer and genetic risks to the public , a s well a s the ofrect of nuclear radia t$ on in increas.* ng diseases other than cancer and Senetic defects, ha'4e been underestimated.
B. With resocet to the nuclear fuel cycle, do not tche sufficient account of the long-term risks of Radon-P2P e,4.ssions (see 4 6. work of C. Keuford, Ph.D. ) and othcr nuclides nresent in mill tailings and odier wastes f rna the nuclear fuel cycle (e.g. U-23h, Th-230, Th-228, W.-2P26, Ra-22h , U-233, an d ?ceny products thereof) which become dose cc,mitnents for the long-term nucli des future when these are released into die environne.nt.
C. With respect to the nuclear fuel cycle, do not est$nate risks o#er the proper period of additional radio-toxicity and bio-hazzdard from the total fuel cycic, which is about 11 millien years according to Dr. Bernard Cohen, U. of Sittshungh, a nuclear energy advocate. Sinc e the danger to peonle and the env$ ronment
, is higher for 11 n3111on yesrs than it would be if the uraniun ore were Icf t in the ground,11 nillion years or thereabouts is the proper period for analyzing the health effects of the nuclear f uel cycle . ;
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RevisedEddleman#3.D I CF&L's ability to safely manage the Shearon Harris Nuclear Power Plant in addition to CP&L's exist! ng 3 nuclear reactors ,
has not been adequately established. U9C I&E retorts sh, ow repeated failures *.n radiation exposure control at CP&L's i
Robinson plant, and repeated breakdowns and management failuren at CP&L's Brunswick plant. Most of CP&L's senior managers on tne Harris site have their only nuclear power ulant experience a$ Brunswick (a very poor training ground) and they are supervised by the same corporate nanagement that has fa$ led to correct the numerous desi E n and overating deficiencies and failures at Brunswick.
CP&L's "mano;p-.cnt carabili ty -enowt" dnem not demnstrata how
.CP&L will ahvoid a continuation of these vroblens at Havris,/ which will be an additi.onal strain on CP&L's nuclear management and
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personnel. CP&L's nuclear managenent and nersonnel have been -
unable to solve eroblems at Brunswick, as shown by the renor&t, exhibits andminst6mmp of }inC inspector Floyd S. Centre 11 in the 1979 remand hearings in this case (CP state), and by the following sworn testinony of nuclear consultant A. R. Jacobstein (MCUC Docket No. E-2 sub hhh, f11ed July 1,1982): CP&L (had a) " Failure to provide adequate staff *.ng and supervision to ir.dentify and/or enrrect an increasing backlog of plant equipment, construction and rexigulatory problems in a timel: nannger during the perio519779-1980"(p.1) .
and his list of probler. (p.5) including " Augmented offgas system problems resulting in a co :plete sy ste7 redesign" p .y m :n(not y n 'yext installed,* O Qeaktiv M
- 6h 7en r. c'te- C"' L M ew u, its l as t ona , saa ur renort, Jan ' 7(O) i t.< 6 J
- " Main condensor failure on both units; hydraulic xxxhkax seisnic ' ' byc(h
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restraint (snubbe") failu"e on both units; service water systen T .- - -
}ggggge; p pipe hanger /rentraint desi.7,n and constructien n o_blems;
- s * *
. sool d0 sign ;
roactor rceirculation numo prob 1 cms; failura of the radioactiva waste mushism p2mcessing systens (RAD'dASTE); Reacter water cleanun i
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system (R'lCU) design probiens; torus nodifications; and Three- l Mile Island reinted issues", which 'Jacobstein goes o'n to describe
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in more de'tuil in his test! mony and numercur exhibits thereto.
All are relevant to this point.
Further, CP&L has been fined reneatedly for violating UFC rules at Brunswick, including disposing lou-1cyc1 radioactive yaste in a local landfill and sending sone to at least one scran dealer, releasing radioactivity unnonitored (Cesium isotones ucre found in a park nerors the river from the plant), etc. CP&L's radiation nrotectinn at Robinson, e soecially re stean generator tentinc, inspection & rectir, has been inadecuate, an shown by overexponures, large radiaticn e. nosures, and at least two largo
's fines by the URC.
And CP&L units have an extraordinary number of the " precursors to severo core danage" identified by NBC and OR"L in their report and draf ta report thercon (Rought Draf t by 09"L, Jun 15, leel:
ppfyJW B;<7T'
" Potential Precursors to Sever Core Damage: Status Su tmary RchArt" identifics 13 of the 1!;1h incidents 1069-79 at CT&L units, including 7 at Brunsuick 2, 3 at Brunswick 1 (making this palant bo th th e unit wi th the ms t, and the plant with tl.c r.ost, such incidents in the st udy period), including 2 at Brunswick 1 and .
3 at Brunswick 2 in the 9 months of 1979 af ter THI-2's accident.
Robinson 2 also had 3 such inxxcidents.
The final renort, released July 1,1982 bv r90, lists C"AL -
1469-80 including 3 of the 30 f the these rates are at or above the national average f,',3.sa with 12 of f,)All 165 such incidents (0 lam:.6 t'.. w
$ ;o g.)g.4,fa-/t c.4 a / uW
'! " ..:- e u ' ' 5:Js Q cpl nost serious. b,O s
for nuclear unita, und sone are extraordinarily above it,
.SMv) $ cpi uc oPk'tw we '**'"" * *"! 3 '"***
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, proposed contention on chemical nollutants/ carcinogens from SHrPP:
A. CP&L's ER (and the DEIS and FES of NBC) take to account of the formation of carcinogenic. chenicals resulting .fron CP&L's discharges into the Harris cooling lake, which include chlor 1ne,
- amnonia, hydra
- ine, etc. (See ER 5.3). ++rrt These discharges can and will interact to form carcinogenic compounds including NC1), NHC12 and NH2 C1 among others. These connounds will uose a risk to anyone swinninC in the lake, and anyone eating fish i
from the lake (due to concentration of carcinogens in the lake food chain). Any di9chn"ges of wated frn, the lake into the Cape Fear Biver will nut these carcinogens 5 nto watev sunnlies of all downriver communities that draw water from the river (e.g. Lillington, etc) and into the river food chains and fish
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stocks in the river and off the NC coast where the Cane Fear empties into the sea.
B. Burveys by the Eaw River Assembly and othe rs have demonstrated that substantial anounts of osanic chemien1s including dyes and atkar phenol-based chenicals that become more carcinogenic af ter rea ctions with chlorine (and with chlorine, av,onia and hydrazine) are discharged into waters feeding the Cape Fear. The data comniled by UNCoCH (see, e.g.
letter of May 11, 1982, EProf. Charles M. Weiss to Christinia Meshaw of Corps of Engineers, Wilmington NC) do not adeo.uately test #cr Invels of mort of these ch emicals, nor does the State of NC (~see printout of Haw River nonitoring stati ons, 5-26-82, -
[ data) test for most of then. Thus, neither CP&L nor anyone else has established thxte actual ziz levels of numerous organize carcinogens in Cr.pc Fear water, nor considered the interaction of these carcinofens and other che t.icals with the .cH7PD di scha r. e s
}.- _lo_
o (e.g. chlorine, hydrazine, anmonia and other chemicals lis ted $ n :
/' E.R. section 5 3) in forming carcinogens ! n dr'nking water, and [.
in putting carcinogens into food chains which culminate in edible I fish, mussels, seaxfood,(e.g. oysters, clans, shrimp) etc. taken {
. = .
by individuals or commercial fishing from the Cene Fear or the '
ocean where the Cape Fear emptics (i.e.g fisheries off cano Pear,
- around tne mouth of die river, and other plcces Capc Fear water '
disperses to). The health effects of these carcinogens, intcluding -
thoce formed by interaction with SEMPP discharce and those nade .
more hazardous by interaction with same, transferred to humans who swim, wash, drink Cape Fear water, or who eat food and seafood wherein 'such carcinogens are concentrated biologically, has not been considered in the E7 (and EIS and UF.TS). Such considerat* on is necessary to nrotect the heal th and safety of the rublic.
/
C. State of NC water nnnitoring has established heavy metals in the haw which feeds the Cape Fear River. (5/26/82 printout includes arzsenic, cadmzium, chromium, cobalt, lead, s
manganese, nickel, zinc; also A1, Cu, fee). Interaction of SHNPP chlorine, hydrazine and other discharres wi.th these .netals could chemically mobilize them (as chlorides, hydrazides, nte) so they will be nere readily absorbed by living creatures in
.the food chain, and by hunans drinking the water or eating the fish, sedrood, etc. in said food chains in the Cape Fear and -
sea fisheries near its dischcrge (within 150 miles or wherever Cape Fear water is discernibly present, i.e. incomoletely mixxed ).
The health effects of such mobilized toxic metals $n drinking water, washing water, bathing water and food on humans have not been pronerly analyzed or taken into account, by CP&L or ?PC Staff.
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