ML20083M143
| ML20083M143 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/11/1984 |
| From: | Fowler L CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), LEGAL ENVIRONMENTAL ASSISTANCE FOUNDATION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8404170480 | |
| Download: ML20083M143 (34) | |
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UNITED STATES OF AMERICA NUCLEAR REGULA'IORY COMMISSION SOCKETED USNRC BEEORE 'IHE A'IU4IC SAFETY AND LICENSING BOARD In the Matter of ) H APR 16 20:54
)
GEOIGIA PO5ER (DMPANY ) Docket Nosr.750-43,4 g 50-425 ct al. ) . . i CI),t'j ,Q[9,<g,;
} .mw..
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
SUPPLEMEtTP 'IO PETITION EOR LEAVE 'IO Ih7ERVENE AND REQUEST EUR HEARING Campaign 'for a Prosperous Georgia Pursuant to an Order dated March 9, 1984 of the Atomic Safety and Licensing Board in the above-captioned proceeding, Canpaign for a Prosperous Georgia Nreby submits the supplement to its Request for Hearing and Petition for leave to Intervene filed January 27, 1984. 'Ihe contentions which Canpaign for a Prosperous Georgia seeks to have admitted in tnis proceeding are as follows: ,
CPG 1
'Ibere is no reasonable assurance that Plant Vogtle will be "substantially conpleted, on a timely basis" as required by 10 CFR part 2, Appendix A,Section VIII(b)(1).
Nur.erous nuclear power plants throughout the United States have been cancelled as a result of declining growth, increasing construction and financing costs, and availability of alternatives. All these factors appear in Georgia. (See CPG Contentions 2, 3 and 4.)
In addition to the three factors outlined above and described in detail in the folicwing contentions, the partners in this project face financing difficulties that any well prevent the coupletion of construction. 'Ihese difficulties have notNri addressed by the Applicant.
'Ihe Georgia Public Service Conmission has recently tuled that a oonplete review of Georgia Power's construction program will be required before any further L
8404170480 840411 l PDR ADOCK 05000424 9 PDR l
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i financing will be allowed. 'Ihis ruling preceded by less than three weeks an
- i. announced bond issuance totalling 5150 million and came in a proceeding in which I Georgia Power requested permission to obtain S750 million for construction-related expenditures. Failure to obtain the financing--a likelihood if the PSC follows j i through on its commitment to review the prudence of the construction program (see CPG Contentions 2, 3 and 4) w ill-likely result in significant delay and/or l
4 cancellation of one or both of the' Vogtle facilities.
i Should the PSC reverse its determination that the construction program of Georgia Power must be reviewed, Canpaign for a Prosperous. Georgia plans to. file suit l to require the PSC to couplete such a review before allowing the financing; Georgia t
- law requires that the PSC approve the " purpose" for which any financing is to be t
used before such financing is pursued. !
f
! Georgia Power itself has inplicitly acknowledged tlat it is in financial
! ~
- trouble. In the current financing proceeding, the Coupany requested a sinking fund j provision to protect potential investors. According to the Company witness (under j cross-examination by Canpaign for a Prosperous Georgia), the last time the'Conpany i
i used such a provision was 1975, a time when the Conpany nearly went bankrupt and ;
t
- required two emergency rate increases to remain solvent.
i .-
! Additionally, Georgia Power is defendant in a suit in Fulton Superior Court, Fulton County, Georgia, for collecting allegedly illegally high rates since October l
1, 1983.
(Civil Action D-6943) Should Georgia Power lose that suit, it would .be required to lower its rates and to refund millions of dollars collected since October. Rates could not be increased unless and-until the Conparry could l
denonstrate the need for such higher rates following full hearings.by the'lubiic i t Service Conunission; this could take up to six months following preparation and b .
l . filing of the rate increase application, which itself could take several months. -
l I h 2 '
[ ,
CPG-2
'Ihere is no reasonable assurance that the production capacity of Plant Vogtle will be needed, as required by NEPA (42 USC 4331-4335) and by NRC regs (10 CFR 50.42) and other laws, rules and regulations.
Originally issued a construction permit for Plant Vogtle in 1974, Georgia Power anticipated annual growth in electricity sales in excess of 10%. Annual electricity sales ' growth by Georgia Pcuer in its territory has declined steadily. In no year since the construction permit was originally issued has grcwth in electricity sales m tched the average on which the Nuclear Regulatory Commission predicated the construction permit, let alone the average which Georgia Power forec.ut. In fact, never has the growth exceeded 6%, the average growth since Georgia Pdwer applied for a construction permit in 1973 has been less than 2%, and the average annual growth in the last six years has been less than 1% (Georgia Power Company Financial and Statistical Review 1973-1983).
w During the Atomic Energy Commission hearings on the construction permit application by Georgia Power (April 16, 1974 transcript), Georgia Power executive Bob Scherer told the Comnission, "I believe there are still inportant economies of scale to be gained in the future, particularly in nuclear generation." Scherer added, "...the demand for electricity is relatively price inelastic." Of course, history has proven him wrong on both counts--as other witnesses at the time warned.
' Die decline in growth described above can be directly attributed to a price increase of nore than 250% from 1972 through 1982.
Consequently, Scherer also erred in his forecasts of peak demnd. He projected that in 1980, peak denand would be 16,728 megawatts while in fact it was 11,154 -
megawatts; he predicted a 1981 peak of 18,528 MW and the actual peak was 11,514 MW; he predicted a 1982 peak demand of 20,528 MW while the actual peak was 10,683 MW; and he predicted a 1983 peak demand of 22,728 MW while the actual peak demand was only 12,257 MW. 'Ibese lowered peaks occurred despite the absence of any serious actions on the part of Georgia Power to control peak demand.
3
Georgia Pwer's load factor has steadily declined in the past decade, from 59.7% in 1973 to just 51'.9% in 1983. This reflects a tremendous peak relative to base load, precisely the kind of demand curve that requires cutbacks on baseload plant construction and increased use of ways to control the peak (such as radio load mntrol) .
Georgia Pwer is already greatly overbuilt. A 1978 Congressional report stated
" Georgia Pwer Campany rated first (in annual mst to consumers of excess generating capacity) with overcharges of S39 million." (Nuclear Power Costs, US House Committee on Government Operationa,1978) Since that tim, the overcapacity problem has beccm even worse in Georgia as several nere coal and hydroelectric plants have begun operation while grw th has not been conmensurate with this new capacity. In fact, territorial kilwatt-hour sales have increased at a rate of less than 1% per year despite some of the nost severe weather conditions ever recorded in Georgia.
In addition to Plant Vogtle, Georgia Power is ;:onstructing nine other generating units, including Plant Scherer Unit 3 (818 megawatts), Plant Scherer Unit 4 (818 megawatts), Bartletts Ferry Units 5 and 6 (108 megawatts), Goat Rock Units 7 and 8 (67 megawatts) and Rocky Vountain Units 1, 2 and 3 (847.8 megawatts) (Georgia Power Conpany Annual Report 1983). Rus, the Conpany's overcapacity problem will be compounded if and when Plant Vogtle comes on line, particularly in view of the increased use of alternative energy sources including conservation.
Even if additional capacity were needed, Plant Vogtle would not be the best way to provide it. Expert testimony before the PSC has stated that it may be more prudent economically to invest in alternatives (particularly conservation and solar c.
energy) than to operate Plant Vogtle even if the plant is cenpleted. Clearly, conservation and solar energy are less injurious to the physical and human environment than Plant Vogtle would be.'
Se Georgia Public Service Commission has also questioned whether Plant Vogtle will be needed. In Georgia Power's nost recent rate case, tne Conmission reversed l 4
its previous practice and disallowed Plant Vogtle's nuclear fuel from the rate base, stating in its final order dated January 17, 1984, "Of course, at the present time, Plant Vogtle is not operational and it is not expected that it will produce electricity for several nore years, if at all...It is the Comission's position, as it has made clear from previous orders, that to be included in rate base an investnent nust be used and useful to the retail ratepayer, if not imediately, at
'least in the reasonably near future. In the context of the nuclear fuel purchased for Plant Vogtle, since the plant itself is not yet in operation, it is obvious that the nuclear fuel purchased by the Conpany.for use in that plant is not currently used or useful to the retail ratepayer, and cannot be for some tine, if at all."
(enphasis added) (Ga. PSC Docket No. 3397-0, Order on Reconsideration, January 17, 1984, pp. 3-4) It is inportant to note that in past cases, the PSC allowed the Vogtle fuel to be included in rate base although thPplant was further frm operation than in 3397-U, denonstrating that a key 5ncern to the PSC is -whether the plant will ever be "useful" as well as wheti.cr it will ever be "used."
A solar water heating system could be installed on every household in Georgia at less cost than the remaining cost of the Vogtle Nuclear Plant. Said water heaters would provide nore energy, would provide nore jobs and would have far less negative environmental inpact than completion and operation of Plant Vogtle.
Furthernere, conservation measures will provide even greater return on the investnent than solar water heating. Yet, Georgia Power does not address these issues. ,
Cleacly, as ' conditions relating to economics, electric consur.ption patterns, and availability of alternative energy sources have cha. W since the construction permit was iscued for Plant Vogtle, Applicant nust make a full assessment of the oJrrent and future need for the plant, as required by the National Environmental Policy Act and NRC regulations. Applicant has not assessed the nec.d for the 5
facility.
CPG 3 .
'Ihere is no reasonable assurance that Georgia Power Conpany and co-owners will have the financial ability to safely operate Plant Vogtle for the period of the license or to permanently shut down the facility and maintain it in a safe condition, as required by 10 CFR 50.40(b), and other applicable laws, rules and regulations.
As described in the previous contention (CPG-2), it is clear that Plant Vootle is not needed. As even Georgia Power acknowledges, the Georgia Public Service Commission ("the PSC") nust ascertain prudence of Georgia Power investments before allowing them to be included in the rate base. If a facility is inprudent or is not used and useful for ratepayers, the PSC should refuse to allow it to be charged to the ratepayers. ,
In determining the prudence of rate base items in a rate proceeding, if the PSC determines that an overcapacity exists-that certath capacity is not useful for .
retail ratepayers-then the PSC will not allow Geo2gia Power to include in rate base the nest expensive (and therefore least prudent) portion of new capacity representing the percentage of overcapacity needed to bring the Conpany down to a i level comnensurate with safe reserve margins. Plant Vogtle is by far the most i
expensive capacity under construction. In fact, Plant Vogtle, according to Georgia Power, will cost S6.6 billion to construct (including financing during construction) while all production plants in operation at the end of 1983 combined cost only $2.9 billion (Georgia Power Conpany Financial and Statistical Review 1973-1983). 'Ibe fact that Georgia Power has sold all electrical capacity in the four Scherer coal- ,
fired un,its through 1992 (Georgia Public Service Conmission Docket #3397-U), ,and ,
that the electricity from the Scherer coal plants will be substantially cheaper than that from the Vogtle nuclear units, increases the likelihood that the PSC will ,
conclude that Georgia Ptwer acted inprublently in constructing the Vogtle nuclear units.
5
In addition, the PSC may icok at the prudence of alternative investm nts, such as conservation and alternative energy. Expert testimony before the PSC in a previous proceeding has stated that it any be more prudent economically to invest in alternatives (particularly conservation and solar energy) than to operate Plant Vogtle even if the plant is conpleted. 'Ihis increases the likelihood that the PSC will exclude Plant Vogtle from the rate base.
As mentioned in CPG-2, considerable evidence from the PSC itself suggests that the PSC will exclude Plant Vogtle from the rate base. Until Georgia Power's nost recent rate hike request, the PSC had allowed the Company to include nuclear fuel for Plant Vogtle in the rate base. In the nost recent rate case (Docket 13397-0),
expert testinony indicated that the financial problems facing Georgia Power were a direct result of overconstruction of power plants. Subsequently, the Commission, in its final order dated January 17, 1984, ruled, "Of c ,ourse, at the present time, Plant Vogtle is not operational and it is not expected that it will produce electricity for several nore years, if at all...It is the Comnission's position, as it has made clear from previous orders, that to be included in rate tnse an investnent must be used and useful to the retail ratepayer, if not in1nediately, at hast in the reasonably near future. In the context of the nuclear fuel purchased for Plant Vogtle, since the plant itself is not yet in operation, it is obvious that the nuclear iuel purchased g the Coapany for use g that plant M not currently used or useful g the_ retail ratepayer, and cannot be for some tim, if at_ all. As a consequence, the Commission finds as a matter of fact tnat the nuclear fuel .
purchased by the Conpany for use in Plant Vogtle should be excluded from rate base."
(enphasis added) (Ga. PSC Docket ho. 3397-0, Order on Reconsideration, January 17, 1984, pp. 3-4) It is inportant to note that in past cases, the PSC allowed the Vogtle fuel to be included in rate base although the plant was further from operation than in 339743, demonstrating that a key concern to the PSC is whether the plant will cver be "useful" as well as "used."
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Petitioner contends that PSC will disallow Plant Vcgtle as not used or useful even if said plant is conpleted and, Georgia Power attenpts to place it in the rate base.
Another potential financial burden which the Conpany has failed to address is the impact of changes in federal income tax accounting being considered by Financial Accounting Standards Board and the U.S. Congress. '1hese changes could remove or reduce tax incentives for unneeded construction, particularly in cases where conservation and other renewable energy has not been aggressively prcanoted.
According to Georgia Power, its total accumulated deferred income taxes (net) at the cnd of 1983 totalled over S800 million (Georgia Power Conpany Financial and ,
Statistical Review 1973-1983); hundreds of millions of dollars more in investment tax credits might be "ficwed through" to consumers by the regulators if the changes being considered are inplemented.
Georgia Power will be unable to safely operate the facility and will.be unable to safely shut down and maintain the facility in the face of these self-inflicted financial situations.
Furthermore, partners in the project will be unable to financially offset Georgia Pcwer's inability to safely operate the plant. Indeed, it may be difficult for the pa'r tners to finance their shares of the facility. '1he financial burden faced by the other partners--Oglethorpe Power Corporation (and its thirty-nine menber electric membership corporations), Municipal Electric Authority of Georgia (and its forty-seven members)' and the City of Dalton-far exceeds their entire
- assets. Recent efforts by the Reagan Mninistration to remove financial guarantees i
for electric cooperatives will, if successful, have substantial inpact on OPC's -
ability to finance its share of the facilities. The Washington Public Power Supply l System's municipal members defaulted on their share of that five-unit nuclear project, and the cities in Georgia may face a similar situation. MEAG has estimated 8
that its share of Plant Vogtle will cost approxirrately $2.3 billion; this conpares with the entire general bonded indebtedness of all its nembers of less than S128 million, less than one-seventeenth their share of Plant Vogtle (Of ficial Statenent, S300,000,000, Municipal Electric Authority of_ Georgia, General Power Revenue Bonds, 1984A Series, Dated March 21 1984).
CPG 4 5 2e applicant has not reasonably explored alternatives to the plant as required by NEPA (42 USC 4332(c)) and NRC (10 CFR 40.42(a)) and other laws, rules and regulations.
Plant Vogtle is the nost expensive constniction project in Georgia history and will cast nore than all currently operating pcuer plants combined. Alternatives including conservation nay cost less than running costs alone for Plant Vcgtle, according to expert testimony presented before the Georgia Public Service Comission.
- A solar water heating system could be installet on every household in Georgia at less cost than the remaining cost of the Vogtle Nuclear Plant. Said water heaters would provide nore energy, would provide nore jobs and would have far less negative environnental inpact than coupletion and operation of Plant Vogtle.
Conservation neasures.will provide even greater return on the investnent than solar water heating. Yet, Georgia Power does not address these issues.
Clearly, alternatives to the operation of Plant Vogtle would mitigate environnental damage, and therefore the NRC would be in violation of the National Environnental Policy Act if it granted an operating license before reviewing alternatives to the operation of the Vogtle Nuclear Plant.
CPG 5 he applicant has not properly assessed the geology of the site and has not properly considered the geology of the site in the e.vJineering design of the project, especially in light of new data made available by the U.S. Geological Survey. R is violates NRC rules on seismic standards described in 10 CFR Part 100, Appendix A, and other applicable laws, rules and regulations.
9
J ,
h e U.S. Geological Survey has postulated the existence of the Millett j cartrquake fault seven miles from the Vogtle reactor site. (U.S. Geological Survey Open File Report 82-156) Petitioner disputes applicant's claim that the fault is not capable.
Further, USGS nas pointed out to NRC that "after several years of intensive i study in the Charleston region, no geologic structure or feature can be identified I
unequivocally as the source of the 1886 Charleston earthquake." (letter from James F. Devine, Assistant Director for Engineering Geology, USGS, to Robert E. Jackson,
) Chief, Geosciences Branch, Division of Engineering, NRC, dated November 16, 1982) i
! We Charleston earthquake was the second worst recorded in American history and
, was nore intense than the San Francisco earthquake. USGS in 1887 said of the i i'
Charleston Earthquake, the " area within which motion was sufficient to attract... attention would be sonewhat more than that, circumscribed by a circle of a J
l thousand miles radius. Six hundred miles from the origins, the long swaying motion was felt and was often sufficient to produce seasickness (nausea)." USGS reported f
that the earthquake was felt in the Adirondacks; Ontario, Canada; Michigan; Milwaukee and Green Bay, Wisconsin; and even Cuba. In eastern Kentucky and i
l southeastern Ohio, " chimneys and bricks were shaken down." USGS went on.to say, "In all of the large towns within two hundred miles of Charleston, more or less damage was suffered...dans were broken (on the Savannah River and near Barnwell)...At
- Augusta,110 miles distant from the epicentrum, the damage to buildings was
! considerable...(For exanple) at the Arsenal, the comanding officer's residence was -
so badly cracked and shattered as to necessitate practical reconstruction...In . ,
I Atlanta, 250 miles distant, there was no worse injury than ' falling dinneys and some clight cracks in the wall, but the houses were instantly abandoned in great alarm i
and confusion by their occupants, and many preferred passing the night in the i
i Ctreets to re-entering their dwellings."
10 .
-The situation in Charleston itself was, of course, even worse. The words of an
. eyewitness survivor are particularly relevant to this proceeding:
- ...It was upon such a scene of calm and silence that that shock of the great
- earthquake fell, with the suddenness of a thunderbolt launched from the starlit l skies; with the might of ten thousand thunderbolts falling together; with a .
force so far surpassing all other forces known to men that no similtude can l truly be found for it. The firm foundation upon which every home had been built in unquestioning faith in its stability for all time was giving way...For j a few moments all the inhabitants of the city stood together in the presence of death, in its most terrible form...
i l
(Within one minute) Every home in the city had been broken or shattered ,md beneath the ruins lay the lifeless or bruised and bleeding bodies of men, women and children, who had been stricken down in the midst of such security as may be felt by him who reads these lines at any rennte distance of time or space." ,
i Even if Applicant is correct that the Millett earthquake fault is not capable-a premise Petitioner disputes--the area is of a similar geology to Charleston and-therefore poses a risk of a devastating earthquake, perhaps as high as XII on the -
, Mercalli scale. ,
Petitioner maintains that Georgia Power has not adequately designed Plant l- Vogtle for such seismic events as are reasonably expected to occur there.
i.
! CPG 6 The applicant cannot guarantee the safe operation of the reactor for the life
- of the plant due to unresolved questions of thermal shock effects on irradiated reactor vessels as required by 10 CFR 50 Appendices A, G, and H and other applicable
~
laws, rules, and regulations.
Thermal shock and the effects of operator response, neutron irradiation, and i pressure vessel steel impurities remains an unresolved scientific question.
1 Pressurized water reactors are susceptible to cracking of the reactor vessel due to l
, severe drops in vessel tenperature under high internal pressure. Neutron irradiation of the reactor vessel, especially at the midline, weakens the vessel and raises'the reference tenperature at a rate dependent on the inpurities in the steel and welds f and the rate of neutron' irradiation. Studies by the Oak Ridge National rahnratories -
chowed that conditions created during a routine transient at Rancho Seco reactor
.near Sacremento, CA might be enough to cause cracks in' older irradiated pressure 11
, - _ . _ _ . - _ _ . _ _ _- . _ _ _ . _ _ . - . _ - . _ . ~ _ _ _ ._ . _ - . . . . _ . _ ,
vessels. Further analysis and nodel' simulations showed that whether pressure vessel l ruptures would or would not occur in a Rancho Seco type transient depended on the operator response. If the nodel assumed correct operator response then the sinulations indicated the pressure vessel would not rupture during the life of the i
reactor. Conversely, if the nodel assuned incorrect operator response, the reactor vessel would be subject to rupture within 3 or 4 years of start-up. 'Ihus, protection fran reactor vessel rupture seems to depend totally on operator response and not on redundant safety features built into the plant (Marshall 1981, 1982).
Se reactor vessel for Plant Vogtle contains 0.10-0.12% copper and 0.012 to 0.020% phosphorous (FSAR sec 5.3.1.1) but no discussion is undertaken by the applicant as to the effects of these levels of inpurities on accelerated brittleness and increased reference tenperature for the pressure vessel. We applicant also does
~
not consider the effect of varied fuel rod geometrics on pressure vessel embrittlenent. In general, the applicant has not ocbsidered the long term safety hazards posed by the problems of thermalshock combined with the effects of vessel material inpurities, embrittlenent due to irradiation, and the confounding effect of operation error. -
- In addition to not addressing the safety factors outlined above, the applicant does not ' address the economic costs of possible solutions to the problems associated with thermal shock. Se applicant states that "no special design features. .. prohibit the in situ annealing of the reactor vessel" (FSAR sec. 5.3.3.1) but do not consider l the costs of this process. If annealing is~ necessary after plant start-up, a .
l shutdown.of two years may be necessary (Marshall 1981). 'Ihe applicant also negl,ects a
.e to nention the economic cost of changes in fuel rod geonetry which might be necessary to decrease irradiation of the reactor vessel.
CPG 7 Applicant has not adequately addressed the value of the groundwater below the
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t
- plant site and fails to provide adequate assurance that the groundwater will not be i contaminated as required by 10 CFR 51.20 (a), (b) & (c), 10 CFR 50.34(a)(1) and 10
- CFR 100.10(c)(3).
( Tne groundwater underlying the Vogtle Plant is a valuable resource whose protection has not been (and cannot be) assured by the Georgia Power Conpany.
! Approximately 300 feet below the surface is the Tuscaloosa Aquifer, a permeable 1
i sand formation which contains large volumes of excellent quality water. Bis j iaquifer is an inportant regional aquifer which supplies water to many cities and connunities across central Georgia and nuch of the South Carolina coastal plain. In eastern central Georgia, the Tuscaloosa Aquifer is the major source of water for many connunities. In Richmond County just north of Plant Vogtle, eighteen j Tuscaloosa wells provide water for 15,000 people. In Girard, which is approximately i five miles from the plant, and M:: Bean, only thirteen miles away, the Tuscaloosa provides drinking water for nost of the conmunity-.reTidents.
i
- he Tuscaloosa Aquifer is not the only valuable groundwater resource underlying
- the plant site. At a depth of approximately 200 feet below surface and a thickness 4
i of approximately 100 feet,~the sand member of the Lisbon Formation also represents a !
! valuable groundwater resource for the area. Cooling system make-up. water wells for f the plant whicti penetrate and are open to both the Lisbon Sand Formation and the 1
i Tuscaloosa Aquifer can provide as nuch as two thousand gallons per minute of I
l excellent quality groundwater. mis groundwater is not only inportant as an f
existing source of drinking water but it is inportant to future development which is l likely to occur along the Savannah River corridor.
- i .
j Directly below the surface at the Vogtle Plant is the water table aquifer.
utile this aquifer is not as areally or vertically extensive as the TuscaloosE or... .
i Lisbon Sand Formations, it is used extensively in Burke County as a source of j drinking water for numerous domestic supply wells, as a saml1 scale agricultural cupply and for some counercial establishments. To these individuals, farmers and.
, businesspeople, loss of this source of water through contamination from Plant Vogtle i l j , 13
could endanger health and cause economic hardship.
In the case of a release of radionuclides to the ground at Plant Vogtle, the water table aquifer would be the first and the nost seriously impacted owing to its -
close proximity to the surface. In the area of Plant Vogtle, soils are permeable and virtually no runoff of rainwater occurs. Any release of radionuclide contaminated water would seep imediately into the ground and eventually reach the water table aquifer. Se sandy nature of the soils and the aquifer material would offer little retention of radionuclides. 2 e radionuclides would migrate with the groundwater and contaminate larger portions of the aquifer.
A significant contamination incident could result in contamination migrating vertically downward from the water table aquifer into the deeper Lisbon Sand Formation and the Tuscaloosa Aquifer. W111e a clay separating the water table from the deeper aquifers may provide some protection for Tne deeper. aquifers, the.50 feet of hydraulic head on the water table aquifer acts as a vertical force on the groundwater, pushing it through fractures or more permeable sections of the clay.
It is knw n that just south of the plant site, this clay changes into a limestone, becoming part of a major regional water supply aquifer, the Principal. Artesian Aquifer.
2e G orgia Power Conpany's record of groundwater protection is not encouraging as denonstrated by events at the Hatch Nuclear Plant. Groundwater underlying Plant Hatch has been contaminated with tritium from a source or sources never fully 3
identified. .
CPG 8 i^"
Applicant has failed to enforce a quality assurance program in the construction
{ of Plant Vogtle that provides adequately for the safe functioning of diverse c.tructures, systems and omponents, as required by 10 CFR 50 Appendix B.
! We success of a quality assurance program is ultimately tied to the generation-
- of adequate confidence concerning the correct functioning of critical nuclear power 14 '
l L
plant systems and conponents.
Repeated violations of NRC regulations by Applicant in the construction methods applied to pipe-fitting and welds nust be interpreted as undermining confidence in the capability of coolant and containment systens to perform their essential tasks.
Although potential deficiencies involving welds in containment liner penetrations had been raised as an issue at least as early as April 29, 1981 (I & E file #X78G03-+118), problems involving the appropriate inspection of welds have occurred at least as recently as Septenber 1983.
Violation Notification has been issued in several instances related to implementing the required test procedures. As indicated in IR 50-424/83-15 Appendix A, the aplicant's construction sheet for examination of reactor coolant pressure boundary welds did not specify the penetrant examination test required by NRC. Such a failure, not singly in the execution of a prescr~ibed test, but the omission of the test from the required procedure, certainly reduces the confidence in the correct functioning of a vital reactor safety system.
Failure to assure that non-destructive testing is conducted consistent with applicable codes led to another violation as reported in IR-50-424 and 50-425. In this instance grit-blasting of the closure head weld cladding of Plant Vogtle Unit 1 (IE X7B610) was performed after liquid penetrant examination of the conponent. This represented not only a departure from the standard procedure of performing the examination on the conponent in its finished condition but an unintended method of degrading a critical steam system conponent after its final installation and .
inspection. 'Ihis is nuch nere than a flaw in an isolated procedure; it is,a basic .-
. s.
i failure in established quality assurance nethodology.
Any adequate quality assurance program nust take into account a broad range of
" planned and systenatic actions necessary" to establish confidence in the system in question. Any quality assurance program predicated exclusively on the l 15 l
I
7 i
inglenentation of dictated procedures without regard to the exercise of critical judgement and standards of' professional practice nust be considered woefully
, inadequate. In an examination of welding activities involving steel structures and i supports in both Units 1 and 2 of Plant Vogtle, the applicant was cited for failure I to include the heat-affected zone (HAZ) of the weld in acceptance radiographs (IR 52 I '50-424 Appendix A Report Details). In response to the notice of violation, the
) applicant defended its procedure by replying that the Code "gives no requirement for including the heat-affected zone in the area of interest" (X7B610). 'Ihis response, which erroneously equates methods of quality assurance with single conpliance to i
j written procedures, was so unacceptable to the NRC that it was directly criticized l by Richard C. f.eWis even though the violation itself had been withdrawn. In his i
l Words, l
" Interpretations of the code by 'Gode Experts' 1 Rake your response appear to set
! cside engineering reason when you consider that 4 based on failure analysis
! experience, the technical world realizes that the heat affected zone of a weld
! is the most critical area of the weldment."
i l In a related matter on November 18, 1982, welding on sections of the containment dome of Unit 2 was conducted during a "very light misty rain." '1he I welding and site QA supervisors felt that the conditions were. suitable for welding since the surfaces of the pieces involved were not conpletely covered with moisture
] (425/82-29-02). 'Ihe inspector, nore concerned with the quality of the weld than '
l with the " General Welding Procedure Specification for Shielded Metal Arce 1
( Processes," prevailed upon the two to stop the work'for the day.
'1he applicant's disposition to prefer restrictive implementation of prescribed -
gocedures to the more circunspect nethods of professional practice does not 4,,
! contribute to confidence in the proper functioning of a congleted and operating '
i .
Plant Vogtle. .
i
! In addition to these procedural aspects of quality. assurance, there are other I
l questions involving the applicant's " controlling the quality of-the ... component or:
16
system to predetermined requirements." In the case of quality control the repeated discovery of inadequacies.and defects in the performance of an essential safety subsystem would generate a cause for concern. Furthernere, at some point in tine, good quality control practice mandates the abandonment of a suspect manufactured article in favor of a nore reliable alternative.
Se standby steam generators selected by the applicant for use as an energency
, backup pcwer system and manufactured by Transanerica Deloval have been riddled with problems. Se applicant was notified of such problems as early as December 1981.
Dat defect involved the governor lube oil cooler assembly and, according to Transamerica Deloval, "could result in engine non-availability." 2e applicant itself reported a starting air valve assembly problem (X7B603-M29) that also "could result in engine non-availability." Likewise problens with piston skirts, reported in October 1982, in the applicant's own analysis (X]p603-M36) could, postulating a mun node failure, "cause the failure of both eng nes, resulting in a loss of power to both trains of the emergency core cooling system and nost of the emergency safety features equipnent."
In a report of a defect in the engine nounted electrical cables submitted to the NRC in Septencer 1983, TD also noted a potential engine performance deterioration.
Se applicant's responsibility for quality control extends beyond collection of individual defect notification and corresponding renedial action. By failing to nake a general assessment of the suitability of the TD diesal generator system for such an extremely inportant emergency function, the applicant has brought its cwn quality control capabilities into question, undermining confidence in the safe 1' .
functioning of its operating plant in direct contradiction to NRC QA requirements.
We number of past and continuing failures of the Georgia Power /Bechtel QA/QC program represents a pattern which indicates an undue risk to the health and safety of the public. Violations involving activities at times resulted from failure to 17
E provide docue nted procedures. (For exanple, Report No. 50-424, 50-425/83-04 regarding concrete QC problems)
'Ihe severity of Quality Assurance performance at Plant Vogtle forced a meting conducted 22 August 1983 at Georgia Power headquarters on the subject of Subcontractor Quality Assurance Performnce Allegation by Pullman Pcwer Products quality control personnel about pipe support installation and piping installation as well as job intimidation of quality control workers. Allegations had been nade try a Walsh Conpany boilermaker that improper welding and work practice had occurred.
Twenty-three concerns which dealt ~ with twelve separate item were discussed.
i Defects were found during the reinspection of Pullman Power Products manufactured piping spool pieces. (Letter from Janes P. O'Reilly to Georgia Power, 28 Septmember 1983,
Subject:
Summary of Meeting--Docket Nos. 50.j24 and 50-425, Vogtle 1 and 2)
Procurement failures continue after numerous I-& E Bulletins from past QA/QC inaction. (for exanple, I & E Bulletin 83-06 " Nonconforming Materials Supplied by Tube-Line Corporation Facilities at Iong Island City New York, Houston Texas, and Carol Stream Illinois;" Westinghouse NLP Printed Circuit Cards GN-275, dated 11/3/83 and GN-298, dated 12/27/83; Westinghouse DS-416 Beactor Tri'p Breakers GN-235, dated June 13, 1983; Westinghouse NSSS Protection System, Belay cards, GN 244 dated July 20,1983; AKR-30 and AKR-50 Electrically Operated Low Power Circuit Breakers; Westinghouse 3" Gate Valve Closure Problem; Westinghouse 4" Gate Valve Closure Problem; Beliance Electric--Cable Terminations; Brown Boveri Electric Inc. 7.5 HK and 15 HK circuit breakers; and American Delaval backup diesel generators) -
Repeated questions have been raised about changes in the Vogtle QAP in addition to the earlier described letter frca Richard Iewis of NRC to Applicant. For exanple, there are questions about the completeness of the Vogtle QAP. (Menorandum i
from James G. Partlow to Assigned Reviewers, 29 November 1983,
Subject:
Determination of Acceptability of List of VEGP itens under QA Program @estions 18
o About Field Change Notices; Request for additional information, letter dated 20 September 1983 from Inster L. Kintner to Doug E. Dutton)
Another threat to the quality assurance, quality control and safety and health of the public is the drug and alcohol use which has been documented and continues to take place on the construction site. 'Ihe breakdown of the QAP results in situations such as that described in Preliminary Notification of Event of Unusual Occurrence PNO-ll-82-ll5,
Subject:
Arrest of Contractor Enployees on Drug Charges Involving Drug Sales and Use, including marijuana, cocaine and valium.
Other allegations from a forner employee pertain to improper QA testing of backfill materials and falsification of backfill QC test results. Four allegations made by a former employee pertain to inadequate concrete QC testing and falsification of concrete QC test records. Two allegations were subsequently partially substantiated. ,
Four violations were also described in the Systematic Assessaent of Licensee Performance Board Assessment July 1,1981 thorugh October 31, 1983. Valve mispositioning has resulted in a S40,000 civil penalty. Testing procedures have identified discrepancies involving cadwell operators. Protection of equipment procedures have been neglected. Failure to establish adequate radiography procedures and welding procedures places the integrity of the entire plant in doubt.
'Ihe couplete failure of the QA/QC program at Vogtle mirrors similar situations at the Zimner Nuclear Plant and the Byron Nuclear Plant. Plant integrity cannot be assured at Plant Vogtle in view of the large number of violations and inadequacies found to date.
CPG 9
'Ibe applicant has failed to submit adequate discussion of novel design features in its preliminary and final safety analysis reports as required by 10 CFR 50.34.
NRC regulations require that Applicant nust include "a sumanry description and discussion of the facility with special attention to design and operating 19
- a. .. -
characteristics, unusual or novel design-features, and principal safety considerations" in its PSAR (enphasis added).
A final safety analysis report (10 CFR 50.34(b)) nust contain "a description and analysis of the structures, systems and cmponents of the facility, with enphasis upon the performance requirements, the bases with technical justification therefor, upon which such requirements have been established and the evaluations required to show that safety functions will be accomplished. The description shall be sufficient to permit understanding of the system designs and their relationship to safety evaluations." (enphasis added)
Despite these specific regulatory requirements the applicant has proceeded with the ingle' mentation of a novel design without providing information adequate for the miniman evaluation of its safety inplications.
For exanple, in a letter directed to Harold Denton dated October 25, 1983, the applicant proposed to eliminate the need to postula'Ee longitudinal and
- circumferential pipe breaks in the reactor coolant system primary loop in the design of VEGP. As a modification of an existing design requirement this cannot be censidered as anything but novel. Unfortunately, even the mininum information required to understand and assess the safety impact of such a departure from
, standard design has been eradicated from the Westinghouse Electric Corporation report wriich provides the impetc._s for the design decision.
In " Technical Bases for Eliminating Large Primary L30p Pipe Ruptures As the Structural Design Basis for Alvin W. Vogtle Units 1 and 2," an analysis is generated from pipe-loading and fracture-nechanics models. The details of the models have been withhud based upon a claim of propriety by Westinghouse. The sanitizatidn of l
the report is so severe that even the figures presenting the conparison of the predictions of these models with experimental results have been removed. ,
It is inpossible for anyone to evaluate or understand the inpact of such an innovation on the safe functioning of the applicant's operating system.
20 i
t
Models of engineering systens have no intrinsic validity. The utility of the model is only realized in the comparison of its predictions with a body of cnpirical data. Without such a conparison a nodel is no nore than a method of generating a desired result.
Furthernore, the claim that the results of a nodel betray a proprietary interest is hard to accept. It is difficult to reconstruct a nodel of even minor complexity from a handful of numbers. Oddly enough, if one could deduce the form of the nodel from a small set of predictions the nodel would probably be so trivial as to have no proprietary value.
W e failure by Westinghouse to provide adequate substantiation of its approach and the applicant's insistance on using the resulting claims as a basis for a major departure in the design of a critical safety system is an unacceptable breech of the regulatory code. .
~
CPG 10 Applicant has not shown that safety-related electrical and mechanical equipment and omponents will be environmentally qualified at the onset of operations and throughout the life of the plant as required by General Design Criteria 1, 2 and 4 of 10 CFR 50, Appendix A and other applicable NRC rules.
Se concept of environmental qualification, i.e. that safety systens nust be able to survive and perform their functions under accident conditions, is
" fundamental to NRC regulation of nuclear power reactors." UCS Petition for Emergency and Remedial Action, CLI-78-6, 7 NBC 400, 408 (1978); CLI-80-21,11 NBC 707, 710 (1980). Safety is the "first, last and perranent consideration" and can ,
lead to the shutdown of nonconplying plants. Power Reactor Develognent Corp. v. ,
International Union of_ Electrical Radio and Machine Nrkers, 367 U.S. 396, 402 (1961).
Applicant has not denonstrated that its present safety systens testing methods, VEGP FSAR Table 3.11.B.1-1, Figures 3.11.B.1-1, 3.11.B.2, are adequate to ensure 21
i effective operation under emergency conditions. For exanple, in investigating accelerated agi of materials, Sandia Laboratory has found that many materials experience greater damage from lower as opposed to raised dose rates when the total integrated dose is the same. Proceeding International Meeting on Light Water Reactor Severe Accident Evaluation, August 1983, TS-3.1; Industrial Research and Development, June 1982 at 55-56. Particularly sensitive are polymers which are found in cable insulation and jackets, seals, rings and gaskets at VEGP. Current methods of testing have used high levels of radiation or only reported the integrated dose (VEGP FSAR, Table 3.ll.B.1-1) and therefore underestimate the effects of the total dose. NUREG/CR-2157, "Occurance and Inplications of Radiation Dose-Rate Effects for Material Aging Studies," June 18, 1981. 'Ihe effects of synergisms, involving the combined effects of radiation, heat and in some experiments oxygen concentration, were also studied at Sandia. the greatest amount of degradation was found upon exposure to heat folRued by exposure to radiation (significantly affected by oxygen during a IDCA sifiulation). NUREG/CR-2156,
" Radiation-Thermal Degradation of PE and PVC: Mechanism of Synergisms and Dose-Rate i 1
Effects," June 1981.
Sandia has also identified other interesting " anomalies." In tests of EPR*
cable material, nulticonductor configuration performed "substantially worse" than single conductor configurations. Sandia concluded that qualification testing employing only single conductors as test specimens may not be representative of nulticonductor performance. Testing of terminal blocks by prior industry standards (function before and after accidents) is not adequate. Instead, applicant nust show '
equipment can function during accident conditions. Sinulation of these condftlons led to instrument reading errors on high resistance instruments of 15-904, which were not conservative. 'Ihis could have led rea1 operators to think that there was adequate subcooling when in fact the degree of cubcooling was significantly less.
UCS Petition for Energency and Remedial Action, glemental, February 7,1984.
22
l l
'Ihe results of these reports have not been applied to environmental j l
qualification testing performd and referenced by Applicant to denonstrate l compliance of safety-related equipment and couponents with applicable standards.
Several pieces of equipment specified in VEP FSAR Table 3.ll.N.1-1 as being environmentally qualified may in fact be urqualified. For exanple, on August 31, 1983, NRC issued a Board notification transmitting a summary of a staff investigation into Franklin Research Center tests on solenoid valves. Over half the valves failed in tests sinulating normal and accident conditions. BN 83-128.
Several valves manufactured by ASCO failed early after exposure to 340 degrees F. , i.e. , they had little or no tim to perform their safety function before failing. Over one year earlier ASCO's own testing had shown poor performnce of these valves, and had reported this to the EQB. The EQB m no from R. Vollmer to D.
Eisenhut (included in BN83-128A) stated the staff " continues to approve" the qualification of valves on the basis of 1978 tests: 'Ihe applicable standard in 1978 was IEEE 382-1980. The EQB concluded that the early failure of the ASCO solenoid valves nakes them unacceptable for use in safety systens and suggested that licensees and applicants be prohibited from using the valves in any application where conditions could be nore severe than those reported in the qualification test report. VEGP FSAR Table 3.11.N.1-1 shows the use of twenty-three separate ASCO sellenoid valves. The function of some of the valves is not listed and in no case is the qualification reference listed.
Also shown as qualified are forty-three (43) separate notor operators ,
nanufactured by Limitorque. The conpany's own testing, see IE Notice 81-29, EDQN No. 1 (September 24, 1981), had shown notor failure on initiation of steam spray accident profile. An update, IN 82-52, singly noted that "this is an ongoing problem." Westinghouse performed further tests and concluded that "the present notor design will not successfully pass Westinghouse cpecified test paramters."
23
S e NRC staff has only confirmed that they will pass IEEE 323-1971, a standard -
icxplicitly rejected by the Comission in CLI-80-21 as virtually useless.
A critical safety couponent in' LOCA is the post IDCA hydrogen recmbiner. One connon type of unit manufactured by Rockwell International has recently been shown to have,a large number of defective parts. EEQN No. 14 in IN 83-72 (10/28/83). For cxample, ITF pressure transducers failed typical IEEE 323 environmental 7
qualification testing, i.e., they would not withstand radiation doses of 1 x 10 rad 4
and showed gradual drifting of readings after 1 x 10 rads. Inspection of VEX 3P FSAR 6.2.5 gives no indication of the manufacturer of the hydrogen recombiner. FSAR 6.2.5.1.1.A states:
All materials used in the recombiners are selected to be conpatible with the environmental conditions inside the reactor containment during normal operation or during accident conditions.
16 ever, no specifics can be fou'.d. FSAR 6.2.5.4.1,briefly summarizes testing on l
the hydrogen recombiners in the Westinghouse development program. S e effect of radiation was not tested. A hydrogen recombiner containing unqualified transducers 4
was shipped to E.I. Hatch 2.
Se applicant has not satisfied 10 CFR 50.48 which requires a showing that
. safety equipnunt is capable of surviving a fire in order to shut the plant down.
Since the NRC has no testing program to establish that the necessary safety equipment is qualified to withstand the fire environment, there is no assurance that the applicant's equipment can withstand such conditions as high humidity, high temperature, spray, corrosive gas, snoke, all of these probably combined with ,
radiation. Comission meeting of January 6,1984, Tr. at 36; UCS Petition for Emergency and Remedial Action, Supplemental, February 7,1984 at 27-29. Wit this assurance, Plant Vogtle should not be allowed to operate.
Applicant has not determined that suitable seismic qualifications of safety related equipment have been used in selecting equiptent for VEGP. Se design criteria and nethods for seismic qualification of equipme'n t in nuclear plants have 24
undergone significant change. Consequently, the margins of safety provided in existing equipment to resist seismically induced loads may vary considerably and must be reassessed. NBC " Unresolved Safety Issues Summry," August 20, 1982.
At the Comission meeting of January 6,1984, Sandia Laboratories reported numrous " shortcomings" in qualifications methodologies used to test safety equipment. For example, conpounded effects (related to the order in which several conditions are tested) can be very inportant and produce nonconservative results (under testing). A broad range of generally accepted methods was also questioned which included:
Can gamma radiation adequately sinulate the effects of beta radiation?
Is it necessary to include oxygen in IOCA sinulation chambers?
Under what circumstances is the Arrhenius a thodology for accelerated thermal aging valid?
Are mechanical stresses significant in aging of electrical equipment (cables, seals)?
i Are the procedures of IEEE standards for qualkfying specific type of electrical J equignent adequate? ,
2ese criticisms and questions about current environmental qualification
- method raise fundamental doubts about the applicant's ability to enploy only environmentally qualified equiptent in all required applications.
Applicant has not accurately defined the parameters of an accident which would affect the operability of safety-related equipment. Furthernere, Applicant has underestimated the period of tim safety-related equipment will be required to cperate. S. H. Hanauer, NRC, perceived this issue as a problem shortly following the accident at t ree Mile Island Unit 2:
"I think that as a result of the TMI accident we have to rethink:
- l. Environmental Qualifications Envelope ,;f' '
- 2. m ings which may have to be qualified Changes in my thinking include:
- 1. Core damage is credible i
- 2. Iong-term plant operation is essential, initiation isn't enough
- 3. IDCA and SLB may not give an envelope that includes 'IMI experience."
+
25
9
-Note from S. H.' Hanauer l NRC Assistant Director for Plant Systens
' Division of Systems Safety April 6, 1979 Such thinking was reiterated by' Robert Pollard, Nuclear Safety Engineer of the Union of Concerned Scientists:
I' tnink it is clear that what is needed is essentially a reassment of the environmental qualifications of safety related equipment in light of lessons learned from the accident."
-Special Prehearing Conference, TMI-l Restart Hearing, Docket No. 50-289, November 8, 1979, TR at 236.
CPG 11 ,
Applicant has not considered generic defects in the Westinghouse PWR constitute an undue risk to public health and safety.
Westinghouse PhR steam generator tubes have shcwn evidence of corrosion-induced wastage, cracking, reduction in tube dianeter, degradation due to bubble collapse w:ter hamaer and vibration-induced fatigue cracks. Qf primary concern is the capability of degraded tubes to mintain their integnity during normal operation and under accident conditions. NRC " Unresolved Safety Issues Summary" August 20, 1982.
'Ihe applicant has not considered the possibility of pressure vessel failure, and no protection is provided against reactor vessel failure in the design of the nuclear facility. Hcuever, as plants accumulate service time, neutron irradiation reduces the m terial fracture toughness and initial safety a rgins. Results from r: actor vessel surveillance prcgrams indicate that up to twenty (20) operating PWR3 ill have mterials with only mrginal toughness after comparatively short periods of operation. NRC " Unresolved Safety Issues Summary," August 20, 1982. '
'Ibe applicant has not considered nor is sufficient technical inforation ; -
currently available to deal with a steam generator tube rupture (SGTR) accident as occurred in a Westinghouse Plant at the Borse11e Nuclear Power Station. NRC BN 83-151. The TMI-2 accident convinced Westinghouse to change the ECCS actuation logic by aliminating the low pressurizer level trip, and this was inplenented by licensees 26
with Westinghouse plants. However, the recent SGTR accident at Borssele actuated the ECCS whian was believed to produce " undesirable attendant problems, such as RCP trip and cantainmnt isolation, which would make accident managenent more difficult." Meno from D. J. Mattson, Director DSI, NRC to D. Eisenhut, Director Division of Licensing, NRC, September 26, 1983. As stated in the above-described uno the NRC staff feels a revision of the ECCS logic to the pre-TMI accident configuration "nas the potential to improve the management of SGTR events."
However, the staff did not conclude whether this " revision would have an overall net increase or decrease in plant risk."
CPG 12 Se applicant has not properly assessed the amuunt of salt and hydrodiloric acid release from the cooling towers and the extent of consequent adverse agricultural and environmental damage in the area of Plant Vogtle.
~
Se VEGP FSAR 5.5.1.1 estimates an approximate salt drif t of 305 pounds per acre per year (see CPSER 5.3.2) within a one mile radius of the cooling towers, assuming a two-unit operation. Naturally this aucunt would decrease at greater distances. No nention was made of hydrochloric acid releases, although this point was brought up bf NRC staff at the Construction Permit Hearing (personal comunication from N. Herring). Hydrochloric acid would be expected to be emitted fran these towers, since chlorine is injected directly into the circulating water system, with a maximum system design chlorine rate of 10,000 lb/ day. Sus there is the potential for the release of thousands of pounds per day of hydrochloric acid which is not addressed in the FES-CP or OMEG (see section 3.6.4.2) and could pose a '
serious environmental problem. In the VEGP-OMER-O-E290.3 the rate of salt,drif t emmission of 305 lb/ acre / year is admitted to be presently considered in the range of potential damage to vegetation.
CPG 13 Petitioner contends that Applicant's pecposed emergency plan fails to ensure 27
that protective measures can and will be taken in the event of a radiological mishap ct Plant Vogtle, as required by 10 CFR 50.33, 50.47, 50.54 and Appendix E to Part 50.
Applicant's E:Tergency Plan states that the Burke County Civil Defense Director will coordinate energency operations at the local level. The plan fails, hcwever, to note that Burke County has no full-tine emergency snager or office. We County lacks a hot-line system tie-in to the State Emergency Managenent Office. W e Acting Director of Emrgency Management of Richnend County, Pam Smith, states that she occasionally has difficulty contacting energency personnel in Burke County due to the lack of a full-time energency planner. (Conversation between Dr. Judy Gordon and Ms. Pam Smith, April 4, 1984) Werefore Applicant fails to show that provisions exist for prcript comunications anong principal response organizations and that each principle response organization has the staff to respond and to augment its initial response on a continuous basis as required by 10 CFR 50.47 (b) (1) and (6).
Similarly, the Plan specifies that the Burke County, Sheriff's Office will provide traffic control, law enforcenent and aid in the event of an emergency. Yet the Applicant fails to show how the limited staff of 28 deputies and one sheriff will be able to effectively handle such a task in light of the hysteria conditions likely to erevail in an evacuation atmosphere.
Se Plan states that the Burke County Hospital Ambulance Service will provide ambulance service in an energency situation, yet the Service maintains only three ambulances. ne Burke County Hospital, which the Plan says will handle the treatnant of both radiation-contaminated and noncontaminated injuries, has a bed capacity of only 52. Such facilities are unlikely to be aufficient to service a large number of injured in the event of a fairly serious radiological accident or of an accident external to the plant which results in injury to the plant, such as an earthquake or a nuclear attack, where non-plant related injuries will also be rampant. Applicant does not address the fact that in light of its close proximity to Plant Vogtle, the Burke County Hoopital might be ordered to evacuate in the event 28
t of a radiation-related accident. Applicant thus fails to show that adequate emergency facilities and equipment to support the emergenecy response are provided and mintained as required by 10 CFR 50.47 (b)(8).
Applicant fails to show that initial notification of the public within the plume exposure pathway Emergency Planning Zone (EPZ) within about 15 minutes will be possible, as required by 50 CFR App E (IV)(D)(3). Applicant has not shown that the local civil defense offices responsible for notification have the necessary equipment, training and unpcwer to activate a prompt notification system. Though Applicant lists a number of warning devices that might be inplemented such as autos and bcats equipped with sirens or loudspeakers, door-to-door contact in remote areas and aircraf t equipped with sirens to be used in remote areas, it provides no assurance that such equipment is available to local governments or that personnel 1
will be available to operate this equipnent. An adeguate county-wide siren warning system which Ms. Smith sees as a top priority in the event of Vogtle operation,
S1,000,000. The County has lacked the funds to install such a system in the past.
(Supra)
In the event of an accident serious enough to require evacuation of all of Richmond County, including the city of Augusta, within 26 miles of the plant, Ms.
Smith estimtes it would take three days to have out tne 145,000 citizens 'af fected.
l, Such a task is not addressed in the Emergency Plan though Applicant should be I
prepared for the displacement of a significant number of the population outside the ,
EPZ due to predictable public response to a limited evacuation. For exanple, during a.
- the accident at ihree Mile Island-2, over 30% of the people living within a fifteen mile radius of the plant evacuated though only a precautionary warning to pregnant women and small diildren within a five mile radius of the plant had been issued.
) The possibility for a similar mass exodus is not addressed in the Emergency Plan.
The evacuation procedures in neither Burke nor Rici. Tend Counties have been tested.
29 4
i Yst, exercises are required to evaluate " major portions of energency response capabilities" and to identify deficiencies "as a result of exercise or drills", by 10 CFR 50.47 (b) (14). We NRC ctaff has concluded that a successful full-scale cxercise is "at the core" of the finding of adequate protection for the public.
SECY-82d185, " Final Amendment to 10 CFR Part 50 and the Appendix E: Madificat. ions to Energency Preparedness Regulations Relating to low Power Operations", May 3,1982.
Se Government Accounting Office has concluded that:
, Testing emergency procecktres with offsite participation would inprove Stat.e and local emergency preparedness...W e types of deficiencies identified during these [NRC-licensed facilities) drills included:
-inadequate connunication between the various agencies participating in the drill, authority for coordinating and inplementing emergency measures, and
-inadequate offsite radiological monitoring procedures.
We believe it is better to identify problems in an emergency drill rather than wait until the actual event occurs. Also, by holding nuclear emergency drills, NRC-licensed pcwer plants and local emergency service agencies have been able to resolve some of the problems that were ident&fied.
j GAO Beport to Congress, " Areas Around Nuclear Facilities Should be Better Prepared
] for Radiological Energencies", EMS 78 llo, March 30, 1979.
We Applicant fails to explain why the plume exposure pathway EPZ for Vogtle has been set at 5 miles rather than the 10 mile radius recommended in 10 CFR l 50.33(y). In light of the severe Pasquille type A weather conditions prevalent in i
the area, the plane pathway should be wider as opposed to more narrow than generally
(
, required. Based on the sensitivity of children (in utro through preschool i
particularly) the plane exposure pathway Energency Planning Zone should be larger for pregnant women and children. Tne tree Mile Island-2 accident caused a
- ctatistically significant rise in the rate of infant mortality within 10 miles of
.~..
the plant. "Managenent of Radiological Dnergencies," Gordon McCleod, M.D., Text of lecture, May 2,1980. McLeod, formerly Secretary of Health for the state of l Pennsylvania, has said: '
Any radiological emergency plan and response in Pennsylvania nust not overlock, j population density for at least 20 miles around existing or proposed nuclear i reactors.
l 30 ,
i I
i 1
Applicant has not shcwn, pursuant to 10 CFR Part 50 Appendix E, IV D.2 and 50.47(b)(6)&(7) that adequate cducation and notification procedures will be followed during nocral plant operation and i t the event of an accident at WP- 3. These requirements include " basic emergen y planning inforation", " general infermation as to the nature and ef fects of radiation", " signs or other measures. .. helpful if an cccident occurs." 10 CFR Appendix E, IV, D.2. Applicant should be required to utilize such methods as billing or home distribution of public informtion brochures to supplemnt eergency information included in phone books as not all residents can be expected to have phones. Provisions for emergency evacuation education of illiterate adults nust also be taken.
Applicant's plan states that possible evacuation routes for persons leaving the reactor site are New River Road and Ebenezer Church Road and evacuation will primrily take place in individially owned autos. Apglicant cannot claim adequacy of this evacuation plan until it identifies the number of autos to be moved, estimate of evacuation time, and under what conditions conpany-owned vehicles will be made cvailable for evacuation purposes.
- Applicant claims that the Department of Energy (Savannah River Plant Operations Office, Aiken, South Carolina) will provide radiological assistance (advice and emrgency action essential for the control of imediate hazards to health and safety) in the event of an emrgency at Vogtle. It fails to addr'sse the possibility that an emrgency situation (for exanple, an earthquake) which threatens the safe operation of Vogtle might also endanger operations at Savannah River Plant. In this ,
cvent, not only would Departnent of Energy officials be prevented from providing, aid to Vogtle, other federal, state and local assistance resources would be divided between the two sites. Applicant does not address the inpacts of sinultaneous evacuation from both plants, or overload of medical facilities and energency vehicles in the event.of injury to persons by the operation of both plants.
31
. _ _ _ _ . _ . _ _ _ . .- . - . _ _ ._ _ . .__ . = _ . - . _ -
1 .
4 .
., w Applicant states that estinates of predictions of atnospheric effluent transport and diffusion during and Unmediately following radioactive releases are i
l based upon the constant mean wind nodel'. Rather applicant should prepare estimates j cncamassing a variety of wind and weather conditions.
In light of the afore-mentioned facts, Applicant has failed to show tlut in the t
j' j
4 cvent of an accident at Vogtle, adequate notification, connunication, education, evacuation, and relocation can take place for permanent, transient, and special -!
I populations within the Emergency Planning Zone. ,
t April 11, 1984 Bespectfully submitted,
^^^^
a.
- Laurie Fowler for
- ;
! i s
Idgal Environmental Assistance Foundation 1102 Healey Bldg./57 Forsyth St. NW j
At~-lanta, GA 30303 404-688-3299 Attorney for Petitioner Canpaign for a Prosperous Georgia ,
i 4
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. . _ _ . . ._____m._._ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _-
r UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION DOCKETED BEFORE THE AICMIC SAFETY AND LICEtGING BOARD USNRC In the Matter of gg GEOiGIA POM R CO., et al. ) Docket Nos. 50-424 and 50-425 (Vogtle Electric Generating Plant, NG lr BRANCH Units.1 and 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing Supplemnt to Petition for Leave to Interver.e and Request for Hearing were served by deposit with the Federal Express agent in the City of Atlanta or by hand delivery this eleventh day of April, 1984, to all parties in this proceeding.
O Laurie Fowler fort Iegal Environmenta. Assistance Foundatioi 1102 Healey Bldg./57 Forsyth St. NW Atlanta, GA 30303 404-688-3299 Attorney for Petitioner Canpaign for a Prosperous Georgia 1
l '
l
'O LNITED STA'IES OF AMERICA NUCLEAR REX 3ULRIORY COMMISSION a
,BEFORE DIE A'ICMIC SAFETt AND LICENSING BOARD In the Matter of )
)
GEOBGIA POER CD. , et al. ) Docket Nos. 50-424 and 50-425
)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
SERVICE LIST Morton B. Margulies, Chairman Atomic Safety.& Licensing Appeal Atomic Safety & Licensing Board Board Panel -
U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris Docketing ar.d Service Section Atomic Safety & Licensing Board Office of the Secretary U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Gusuve A. Linenberger Ber M M. Bordenick, esq.
Atomic Safety & Licensing Board Office-of the Executive Legal U.S. Nuclear Regulatory Comission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Atomic Safety & Licensing Board Panel Carol A. Stangler U.S. Nuclear Regulatory Comission 425 E11clid Terrace Washington, D.C. 20555 Atlanta, Georgia 30303 Douglas C. Teper Dan Feig 1253 tenox Circle 1130 Alta Avenue Atlants, Georgia 30306 Atlanta, Georgia 30307 i
Jeanne Shorthouse George F. Trotbridge 507 Atlanta Avenue Ernest L. Blake, Jr.
Atlanta, Georgia 30315 David R. Imwis Shaw, Pittman, Potts & Trowbridge .
Janes E. Joiner 1800 M Street, N.W.
Sumer C. ' Rosenberg Washington, D.C. 20036 Troutman, Sanders, Lockerman & Ashmore *. . . . '
127 Feachtree Street, N.E. Ruble A. '1homas Atlanta, Georgia 30303 Southern Conpany Services, Inc.
P. O. Box 2625 Birmingham, Alabama 35202 9
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