ML20091P562
| ML20091P562 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/11/1984 |
| From: | Trowbridge G GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| Shared Package | |
| ML20091P551 | List: |
| References | |
| NUDOCS 8406130101 | |
| Download: ML20091P562 (8) | |
Text
F S
J C00KETED tr;'. rq 3""* 11' 1984
'84 JUN 12 All :51 UNITED STATES OF AMERICA NUCLEAR REGULATORYdCOMMISSION tn BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
)
Docket Nos. 50-424
)
50-425 (Vogtle Electric Generating Plant, )
Units 1 and 2)
)
APPLICANTS' RESPONSE TO NEW INFORMATION SUBMITTED BY GEORGIANS AGAINST NUCLEAR ENERGY AND CAMPAIGN FOR A PROSPEROUS GEORGIA IN SUPPORT OF THEIR PROPOSED CONTENTIONS During the Special Prehearing Conference of May 30, 1984, Petitioners Georgians Against Nuclear Energy (GANE) and Cam-paign for a Prosperous Georgia (CPG) submitted some new infor-mation in support of their proposed contentions.
Applicants requested and were granted an-opportunity to respond to this new information.
Tr. at 84-85; Tr. at 164-165.
GANE-2 (Cumulative Effects)'and GANE-7 (Groundwater)
GANE submitted a letter dated May 29, 1984, from
-William F.
Lawless to Danny Feig, as additional' support for proposed ~ contention GANE-7 (on groundwater) and perhaps-for-e
- M E
_,..[.l.g r*M
\\
proposed contention GANE-2 (on cumulative effects).
See Tr. at 107-108, 135.
The content of the letter, however, is not relevant to GANE-7.
It does not relate to GANE's allegation that operation of Plant Vogtle might result in groundwater contamination.
In-stead, the letter addresses nuclear waste burial, and as point-ed out during the Special Prehearing Conference, no nuclear waste burial is proposed at the Vogtle site.
Tr. at 136.
GANE subsequently argued that the letter bore on cumula-tive groundwater contamination.
Tr. at 136-137.
If at all, this assertion is relevant to GANE-2.
But the Lawless letter does not address cumulative effects.
It does not even mention Vogtle or the contamination of groundwater under the Vogtle site.
Indeed, the explanatory note accompanying the Lawless letter states that the letter "could fit somewhat under cumulative effects but only weakly."1/
The explanatory note also indicates the true target of the letter.
This is a generic issue that indirectly applies to Vogtle.
The NRC nuclear waste regulation-(10 CFR Part'61) regulates commer-cial nuclear generated waste such as will be generated by Vogtle.
The NRC regulation is deficient for vegetative uptake;-does or may not apply for the EPA RCRA regulations-and 1/
Similarly, Mr. Lawless' comments during.the Special Pre-hearing Conference. failed to address Plant Vogtle.
POr. Law-less' discussion of the levels of radioactivity in burial groundwater (Tr. at 119) and levels offradioactivity on the Sa--
vannah River Plant site is simply' irrelevant. --
e-V W
i 0
(
all NRC regulated burial grounds may be in violation of RCRA; and possibly may be defi-cient in their lower central limit for transuranic waste.
The argument is this:
additional radioactive wastes generated by power plants add othe
[ sic] the unresolved issues of vegetative uptake, possible RCRA violations, and transuranic waste.
New power plants (nucle-ar) should not be licensed (or allowed to be built) until this issue is addressed.
~In short, Mr. Lawless is attacking the Commission's regulations governing waste disposal -- regulations not even at issue in this proceeding.
Furthermore, for the purposes of the Commission's NEPA review in this licensing proceeding, the environmental ef-fects of waste disposal are established by table S-3.
10 C.F.R. 5 51.20(e).
GANE-8 (Quality Assurance)
GANE also submitted, as additional' support for GANE-8 on quality assurance, a letter from Clinton Sumrall to Rockwell In-ternational Corporation, and a letter from Rockwell in response.
Tr. at 49-50.
Mr. Sumrall asserted that material tests, required of pressure-retaining valve components under Section III of the-ASME Boiler'and Pressure Code in order to ensure pressure'_integ-rity, should be applied.to.all active components _of Rockwell bal-
-anced disk main stream. isolation valves with' air / spring.
actuators.
I
/
j
~'
+
g
i t
-)
Mr. Sumrall's letter has nothing to do with Applicants' quality assurance program.
As the Sumrall letter makes clear,Section III of the ASME Boiler and Pressure Code does not apply to non-pressure-retaining valve components.
Thus, no violation of these code requirements is involved.
Mr. Sumrall does not al-lege any deficiencies in other tests which are conducted to as-sure that valves and their actuators have been seismically quali-fied.
CPG-ll (Unresolved Safety Issues)
At the Special Prehearing Conference, Howard Deutsch pro-vided additional information is support of CPG-11.
Tr. at 80-85.
In particular, Mr. Deutsch referred to the FSAR, p. 5.4.3-9, as an admission "that in certain localized cases that [ sic] there is thinning and intergranular stress corrosion."
Tr. at 81.
The paragraph to which Mr. Deutsch refers, however, is taken out of context.
As is evident from this section of the FSAR
($ 5.4.2.4.3),
localized corrosion rates greater than that nor-mally associated 'ith Inconel 600 have been experienced only in stream generators that did not use all volatile treatment-(AVT).
The FSAR explains that the use of AVT. minimizes the possibility of this phenomenon. -CPG has provided no basis for. disagreement-
~
~
with the FSAR.
CPG has still failed (1) to demonstrate the safe-
-ty significsnce of this issue.with respect to Vogtle and'(2) to expl'ain how the fashion'in which the. application deals with the
9 matter is unsatisfactory or why there has been insufficient as-sessment of a particular type of risk.
Gulf States Utilities Company (River Bend Station, Units 1 and 2), ALAB-444, 6 U.R.C.
760, 773 (1977).
GANE-12/ CPG-12:
Chlorine GANE and CPG amended contention 12 to replace all references to hydrochloric acid with references to chlorine gas.
CPG Amend-ment to Supplement to Petition for Leave to Intervene and Request for Hearing, filed May 27, 1984.
Tr. at 86-87.
At the Special Prehearing Conference, Mr. Deutsch asserted that "there is a potential for elemental chlorine to be released."
Tr. at 92.
Read literally, the contention lacks factual basis as a sim-ple matter of chemistry.
When chlorine gas is injected at the circulating water pumps, the gas is dissolved in the water and hydrolyzes rapidly according to the following equation:
H+ + HOC 1 +-Cl
~
C12+H2 This hydrolysis is substantially complete in less than one sec-ond. -The percentage of molecular chlorine (C1 gas).in an 2
acidic water solution of 10 ppm chlorine at 77*F and a pH of 4'5 would be 0.01%.
At higher pH values and temperatures, the per-centage of. molecular-chlorine diminishes.
Perhaps Petitioners were attemptingito. expand the' contention
~
to address HOCl (hypochlorous ~ acid). 'However, if so,1 Petitioners 1 made-no attempt to: quantify the= amount.of chlorine ~,- in,whatever O-t
^'
J
')
form, that they think would be released or to discuss its signif-icance, if any; and they certainly did not present any signifi-l cant new information that would warrant a reassessment of evalua-tion performed at the construction permit stage.
See CP-ER at SS 3.7 and 5.3.2; CP-FES at S 5.5.1.1.
See also Applicants' Re-sponse to GANE and CPG Supplements to Petitions for Leave to In-tervene, at 31 n.24 (May 7, 1984); Tr. at 93-94.
Respectfully submitted, SHAW TTMAN PO S & TROWBRIDGE Nff/
4 Cedrg9 F. ' Trowbridge,
.C.
7 Ernest L.
Blake,.P.C.
David R. Lewis Counsel for Applicants Dated:
June 11, 1984 E
~ -
--?
k i1 1
4 y
s
f June 11, 1984 l
00CFETFn C3LME!! ~
UmRc UShne
'84 JW 12 Alpw3rrED'8drufES1hPA1AAEh1CA NUCLEAR REGULATORY COMMISSION CFt c_. Oi
.ie.
LFi:- !! -.
00'MLitr40 4 SEno 00CdllthG & M M BRANCH URANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
)
Docket Nos. 50-424
)
50-425 (Vogtle Electric Generating Plant)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to CPG's Request for a Waiver of 10 C.F.R.
S 51. 53 (c), "
dated June 11, 1984,and " Applicants' Response to New Information Submitted by Georgians Against Nuclear Energy and Campaign for a Prosperous Georgia in Support of Their Proposed Contentions," dated June.11, 1984, were served l
upon the persons on the attached Service-List by deposit in the United States mail, postage prepaid, this lith day of June,~1984.-
'f y
'MDDc -
dg David R. Lewis
'd DATED:-~ June 11, 1984'-
m u
~
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
i
)
l GEORGIA POWER COMPANY, ET AL.
)
Docket Nos. 50-424
)
50-425 (Vogtle Electric Generating Plant, )
Units 1 and 2)
)
SERVICE LIST Morton B. Margulies, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Gustave A.
Linenberger Docketing and Service Section Atamic Safety and Licensing Board Office of the Secretary U.S.
Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H.
Paris Bernard M.
Bordenick, Esq.
Atomic Safety and Licensing Board Office of Executive Legal Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Atomic Safety and Licensing Board Tim Johnson Panel Campaign for a Prosperous Georgia U.S. Nuclear Regulatory Commission 175 Trinity Avenue. S.W.
Washington, D.C.
20555 Atlanta, GA 30303 Douglas C. Teper Carol A.
Stangler 1253 Lenox Circle 425 Euclid Terrace Atlanta, GA 30306 Atlanta, GA '30307 Jeanne Shorthouse Dan Feig 507 Atlanta Avenue 1130 Alta Avenue Atlanta, GA 30315 Atlanta, GA 30307 Laurie Fowler & Vicki Breman Legal Environmental Assistance Foundation-1102 Healey Building Atlanta, GA 30303
-,