ML20082T703

Amend to Jacksonians United for Livable Energy Policies Request for Adjudicatory Hearing on Amend 10 to License NPF-13 & Petition to Intervene.Procedural & Standing Requirements Met.Certificate of Svc Encl

ML20082T703
Person / Time
Site:	Grand Gulf
Issue date:	12/11/1983
From:	Stewart C AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8312160100
Download: ML20082T703 (7)

Text

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December 11,1983 00CKETED UNITED STATES OF AMERICA US E NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIN BNRW P2:37 OFFCI ;F T . :.-

- In the Matter of ) GCCEEii:G s 3EP" ORANCH

)

MISSISSIPPI POWER & LIGHT ) Docket Nos. 50-416 COMPANY, et al. ) 50-417

)

(Grand Gulf Nuclear Station, )

Units 1 and 2) ') SERVED DEC 151983 AMENDMENT TO REQUEST BY JACKSONIANS UNITED -

FOR LIVABLE ENERGY POLICIES ON BEHALF OF ITS MEMBERS FOR ADJUDICATORY HEARING ON AMENDMENT NO.10 PETITION TO INTERVENE AND REQUEST FOR HEARING G Petitioner, Jacksonians United for Livable Energy Policies,is an organization 1.

which exists to articulate public concern on energy matters.

- 2. Cynthia Ann Stewart is a member and chairperson of Jacksonians United for Livable Energy Policies (JULEP) and a resident of 950 North Street, Apartment 7, Jackson, Mississippi.

3. Jan Hillegas is a member of JULEP and a resident and homeowner in Jackson, Mississippi, at 4117 West Capitol Street.

4. Dale Wallace is a member of JULEP and a lifelong resident and farmer in southwestern Warren County, Mississippi, acout 15 miles northeast of the Grand Gulf Nuclear Station; his mailing address is Route 2, Box 186, Vicksburg, Mississippi 39180.

5. The above members have authorized JULEP to act on their behalf in this proceeding (affidavits attached). .

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l 6. The changes made by Amendment 10 include redefining Operanility range for High Pressure Core Spray (HPCS) until the first refueling outage due to water level instrumentation inaccuracies at low pressure (MP&L letter dated August 1,1983). As

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page 4 of the NRC Safety Evaluation of Amendment 10 indicates, the belief that little or no change in the peak cladding temperature would be expected is based on a best+ stimate basis, which indicates that few or no criteria are available for this determination. A serious situation could result if this assertion, which may be based on no or insufficient evidence, proves wrong. Given this, the matter should be fully explored through a hearing before proceeding.

7. Amendment 10 permits suspension of Specification 4.0.4 to allow the plant to attain operating conditions necessary for ADS Trip System surveillance testing (MP&L letter dated June 14,1983). The Safety Evaluation stresses that the surveillance test must be completed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. There is no indication and no information that 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a short enough period to insure safety. It appears to be an arbitrary length

, of time.

8. MP&L seeks suspension of Specification 4.0.4 to allow Grand Gulf Unit 1 to attain operating conditions necessary for Scram Discharge Volume surveillance testing

. (MP&L letter dated August 1,1983). The Safety Evaluation, on page eight,indicater that this test must be completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after attaining sufficient rod density. Again, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> appears to be an arbitrary figure, with no indication or information to support the assertion that it is sufficiently short to insure safety.

9. Grand Gulf Unit 1 is the largest boiling water reactor of its kind. There is no experience at other plants like it on which to draw in making decisions affecting safety.

There is, therefore, every reason for caution in suspending and making exceptions to

. specifications affecting safety. .

10. The Grand Gulf containment building suffered tornado damage and, more recently, fire damage. The licensee has been found negligent and heavily fined for violating simple security procedures. The Nuclear Regulatory Commission is currently investigating

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allegations that Mississippi Power and Light Company falsifiul plant training records at Grand Gulf. There is every reason for vigilance in regulation.

11. There is no reason for the NRC to grant Amendment 10 in such a speedy fashion. The reason offered, that the NRC staff failed to make a timely evaluation of the amendment in behalf of the public interest, might be grounds for reviewing the performance of staff members,but should not be legitimate ground for failing to protect the public

.* interest fully, including the right of the public to a hearing. As Scenic Hudson Preservation

. Conference v. Federal Power Commission,354 F. 2d 608 (1965), demonstrates, the NRC, through its Atomic Safety and Licensing Board,is under an obligation to consider all 4 relevant informatios in an effort to protect the public interest, especially in an issue of this

! type where concern for public health and safety is so great. It is imperative here, as it was I in Scenic Hudson, that the appropriate regulatory agency consider all factors relemnt to the public interest.

12. The efforts of JULEP to request a hearing demonstrate the disadvantage of ordinary citizens in trying to exercise their rights. JULEP cannot afford legal counsel or l

• the technical experts available to the licensee and the NRC. This underlines the need for and importance of a hearing on the aforementioned issues.

l JULEP, by its amended petition for intervention and request for a hearing, has met l

procedural and standing requirements and presented serious safety concerns that need to be addressed in a hearing. The United States Nuclear Regulatory Commission should grant t

the request for a hearing.

Cynthia Ann Stewart Chairperson, JULEP

_ _- .m .

. - _ . _ . - _ _ . . = . _ _ - _ . . _ . - .. _

December 11,1983 I, Cynthia Stewart, authorize Jacksonians United for Livable Energy Policies (JULEP) to act on my behalf in petitioning to intervene and requesting a hearing before the United States Nuclear Regulatory Commission Atomic Safety and Licensing Board.

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December 11,1983 I, Jan Hillegas, authorize Jacksonians United for Livable Energy Policies (JULEP) to act on my behalf in petitioning to intervene and requesting a hearing before the United States Nuclear Regulatory Commission Atomic Safety and Licensing Board.

AW u a Witnessed by:

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December 11,1983 I, Dale Wallace, authorize Jacksenians United for Livable Energy Policies (JULEP) to act on my behalf in petitioning to intervene and requesting a hearing before the United States Nuclear Regulatory Commission Atomic Safety and Licensing Board.

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Witnessed by:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

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.. hF BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'83 DEC 14 P2:37 t In the Matter of ) CII;

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Docket50-417 b.'53$0hhc MISSISSIPPI POWER & LIGHT )

COMPANY, et al. )

)

(Grand Gulf Nuclear Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " AMENDMENT TO REQUEST BY JACKSONIANS UNITED FOR LIVABLE ENERGY POLICIES ON BEHALF OF ITS MEMBERS FOR ADJUDICATORY HEARING ON AMENDMENT NO.10"in the above<aptioned proceeding have been served on the follcwing by deposit in the United States mail, first class, this 12th day of December,1983:

Troy B. Conner, Jr., Esq. Atomic Safety and Licensing Board Conner and Wetterhahn, P.C. Panel (4 copies)

*. U. S. Nuclear Regulatory Commission 1747 Pennsylvania Avenue,N.W.

Washington,DC 20555 Washington,DC 20555

• Atomic Safety and Licensing Appeal Mr. Ken Lawrence JULEP Board Panel P. O. Box 3568 U. S. Nuclear Regulatory Commission Jackson, Mississippi 39207 Washington,DC 20555 Robert B. McGehee Docketing & Service Section Wise, Carter, Child & Caraway Office of the Secretary

- 925 Electric Building U. S. Nuclear Regulatory Commission P. O. Box 651 Washington,DC 20555 Jackson, Mississippi 39205 Mississippi Power & Light Company NRC Staff, c/o Mary E. Wagner, Counsel ATTN: J. P. McGaughy, Jr. U. S. Nuclear Regulatory Commission Assistant Vice President, Nuclear Production Washington,DC 20555 P. O. Box 1640 Jackson, Mississippi 39205

• b Cynthia Ann Stewarti ,

Chairperson, JULEP ,

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