ML20105B615
| ML20105B615 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/24/1992 |
| From: | Marucci M CO-OPERATIVE CITIZEN'S MONITORING NETWORK, INC. (CCMN |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#392-13214 92-665-02-OLA, 92-665-2-OLA, OLA, NUDOCS 9209210060 | |
| Download: ML20105B615 (17) | |
Text
2/f P.O. Box 1491 CCMN New Haven, CT
-t 06506-1491 WMNN/ENW 203-387-6937
.o, een p asp Co Operative Citizen's Monitoring Network,Inc.
Hotline: 1-800-475-2266 August 24, 1992 Atomic Safety and Licensing Board Panel Nuclear Regulatory Commission Washington, D. C.
20555 R E : Doc!< e t no.50-336-OLA (design of Spent Fuel Pool)
FOL. No. DPR-65 ASLBP No. 92-665-02-OLA
Dear Administrative Judges:
We have four primary contentions:
1.
There is no basis for the NRC to rule that "no significant risk" is involved in the issuance of the design change that was issued to address the criticality errors found at Millstone 2.
2.
An environmental and health study is needed so we can know the effects from releases of varying amounts of the current allowable radioactive inventory of the spent fuel pool.
3.
Immediate installation of criticality monitors is needed.
4.
Immediate action is needed to stop NU from contaminating the new steam generators until our concerns for the safe storage of the spent and new fuel is addressed.
Please see the.following material and the attached documentation and affidavits of.Dr. Gordon Thompson and Dr. Michio Kaku in support of these contentions.
CONTENTION 1:
There is no basis for the NRC to rule that "no significant risk" is involved in the issuance of the design change that was issued to address the criticality errors found at Millstone.
The accident scenarios used in the safety analysis reports assume the use of the " neutron flux trap" principle as valid, but this principle as applied at the Millstone 2 spent fuel pool has been called into question by LER 92-003-00.
In the May 1986 safety analysis it was assumed that the issue 9209210060 920824 PDR ADOCK 05000336 Q
PDR CCMN Contentions regarding Millstone 2 - FINAL VERSION - PAGE 1 7 $O$
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CCHN_' Contentions regarding Millstone 2-
-FINAL VERSION - PAGE 2 of i nad ve r t e n t__. c r i t i ca l i t y in_the_ pool _was unlikely and therefore was not considered in the accident. scenario.
CONTENTION 2:
An environmental and-health study is_needed so we can know the1 effects from releases of varying amounts of the current allowable radioactive inventory of the spent fuel. pool.
The1use of Boroflex as: the neutron-flux trap in use in the.old Region 1.
which'has been renamed Regions A and B by amendment 158._ is now considered by us to be under serious question.
NU has failed to release to us there criticality calculations that support their contention that pool redesign meets current NRC safety standards.
HNU insists that their calculations were not the basis of-the redesign, but that the design is-based on Holtec's work which is verified by Holtec's quality assurance v
program.
Dr. Stanley Turner of Holtec said-the calculations and runs were independent'ly: verified by professor-Vernetson.
from'theiUniversity-of Florida under contract sith Holtec.
Dr. Turner told us that.the inhouse r.u n s and calculations are considered' proprietary _and neither Northeast Utilities or the NRC has them.
.Since we have~ been told Holtec's-information' is the basis for the safety of the redesign allowed by amendment #158 we need the' assistance of the NRC to access those experiments.and calculations that were-done by Holtec,Inc.
Without this informa' tion from NU-and Holtec we cannot know if
.the redesign improves or--makes worse the criticality situation
.for all of. Re g i on 1.: or the newly sectioned Regions-A and B as it-is now used-or wilI be-used.
Since4theLNRC does not-have this~information they cannot be-certain either.
Therefore we feel'that-the issuance of-this
-1icense amendment is premature, CONTENT.10N 3: Immediate11nstallation of-criticality monitors is i
needed.
'The removal of requirements for neutron flux monitors in the i
Millstone 2 spent fuel pool was. improper in light of the fact L
-that before-the-license amendment was issued to allow no inpool-criticality monitors, the NRC was aware that-the criticality. safety margins were being-questioned.
Therefore we contend that without criticality monitors in that pool we
CCMN Contentions regarding Millstone 2 - FINAL VERSION - PAGE 3 will have no prior warning if a dangerous neutron multiplication is happening.
- aACCIDENT SCENARIOS ***
Tbtre are several backup systems that can add water to the pool if the level gets too low.
Even if all the usual automated systems that add water to the pool tail because of power loss and reactor shutdown, there is always the fire main from which water can be d r a w r..
Consequently neither the NRC or the Industry consider loss of coolant water to warrant thorough analysis.
At times when the NRC and Industry are forced to consider coolant loss or forced cooling system failure, as during the proceedings related to safety analyses of increased thermal loa ( to spent fuel pool that make bolloff a plausible concern, they get around it by considering only the consequences of a partial boilott without justifying that position.
The worst case bolloff considened for the Millstone 2 pool is described in their May 1966 documentation for rerack license
- 117.
In the safety analysis a PARTIAL BGILOFF leaves water of 10 feet over the assemblies which acts as a radiation shield.
4 These parameters generate misleading information on the extent of exposure to people and the environment in the case of a more severe partial boiloff or a full boiloff of the spent fuel pool water.
With a partial boiloff that were to expose the tops of the assemblies, sufficient releases would be expected and there a
would be a need to complete evacuation plans for such an event.
This wasn't done.
The worst accident scenario analyzed in the FSAR for the spent fuel pool is a cask dropped into the pool which causes the rupture of 500 rods.
There is no loss of water and the damaged rods remain under water and the radiation is mostly contained in the water.
The water acts as a radiation shield and what does get released into the air is filtered through automatically activated air ventilation and filtration systems that are assumed to be working.
This postulated incident does not happen concurrent with a fire, or while major problems with the reactor are taking precedence over the pool.
No criticality is occurring concurrently and the cooling system is working.
Nobody forgets and leaves the bay door open to the outside.
,.~.
-. _.. _~. _ -.
CCMN Contentions.regarding Millstone 2 - FINAL VERSION - PAGE 4
. Consequently the_ worst case-scenario res71ts in theoretically low levels _of exposure to the public.
This scenario does not consider-_ forced coolant failure, similar-to what happened on July 6th, to occur-simultaneously with the dropped cask or at the time
- of an' emergency full-core. offload or recent refuel.
It does not consider the heat and radiation from a localized critical (ty at the time the cask is dropped..nor when there is a cooling-failure.
Some situations, such as criticality which are susidered improbeble because:of design safeguards, become possible because of design or material failure, as is the case now with the uncertainties associated with the-mathematical-modelin6 and the
'Boroflex-breakdown and erosion shich we understar" +he NRC has r.9erts on_in addition to LER-92-003-00.
These t.'
tional reports have to'do~with the erosion in the Borofle-panels that' was observed when the panels were pulled for inspection. We need
' the NRC and-the company to release this information.
In'the real world hardly ever does just one thing-go wrong at a-t'i m e. Since the worst case senario that the. industry and-the regulators-use to assess damage and risk to the environment and people is predicated on'only one thing going wrong at_once, then
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it cannot be' considered-to. realistically predict risk and damage to the public.
July 6,1992 Spent Fuel Pool Event **
On July'6, 1992 the forced cooling system of'the pool at Millstone-2 became non-operational because of a power loss and the Shutdown _ Coolant System backup. failed to_ operate.
The loss of? power that led to loss-of-forced cooling.was-not -compounded by other situations like a fire or problems with an operating reactor.:
Yet 3 days before on July 3rd, the full-core had been placed in_the pool'which greatly increased the thermai load of
- the pool.
-When=the cooling system failed the -Water temperature rose. rapidly.
Because.the. Shutdown. Coolant System was not properly activated, no backup' cooling was provided-and. ten thousand gallons of-water were siphoned out of the pool causing ~the level to dropL1 1/2 feet.
There' existed the potential, if not the actualization.-of localized boiling, if_the water that wasLinadvertently siphoned
-out'of-the pool was not pumped back or other water added quickly, there was' danger of--a' complete pool bolloff in less than the 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> quoted byfNU.
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CCHN-Contentions regarding Millstone 2-FINAL VERSION - PAGE 5
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-I The-pool temperature at! start;of eventL(8:55) was 88 degrees and j
- w h e n' c o o_l i n g _~ w a s resumed 2-1/3' hours later, the temperature had:
' climbed _4: degrees'F.
These are_ average or bulk _ temperatures.
'Sinceswe/ don't;have the actualJ temperatures at different levels in1 Region A where?the full-core is being stored, we can't know how'close to.a-localized bolloft the pool came or if'there was-in y
f ac t. l oca l i zed tuo l l'i n g.
-Because no other compounding events happened concurrently that prevented-people from replacing the water that had been lost-and restarting the cooling system, no major bolloff occt red.
j Durucurrent understanding-of July 6 is as follows:
3
-1.
The control room priority was to restore power after a 1460 kv j:
- line wa s -- a c c i d e n t a l l_y lost during a maintenance procedure. 10ne of-the backup. generators was down:for maintenance and the other-2
's t a r t e d,-' b u t failed to generate esectricity.
They had to manually transfer. power from somewhere else.
2.
Three valves were manually opened from the control room to
' allow waterLto--be:suctioned-from-the pool, sent through one of the
' shutdown heat exchangers, and returned to the pool.
3.
2The-water went-from the SF pool to the-reactor vessel (which had no fuel in it) and lifted-off the top or head-of the reactor.
'A.
The_ spent-( f ue li wa ter, now _ mixed with primary coolant _watar,
-ov'erflowed-into-the fuel transfer canal that had recently been
= drained;
- 5...The sump vaIve had_been.lett open in the saddle 'of the canal iwhich is about six feet lower:than the-canal ~ floor.
The water
'flowedi into-the saddle, through the open valve-into a sumpvarea 22 feet-below the: containment.
Ei.-
The sump pump could.not handle the flow.
7;
,The' water _then backed up and; overflowed ento the containment
- f l oor.
8.
The workers in the containment called the control room to let them know that-water was flowing from around the reactor vessel.
9 '.
After power-was restored they pumped this water back into the
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'CCMN1 Contentions.regarding Millstone 2 - FINAL VERSION.- PAGE 6 SFP even though:it was=mixediwith primary coolant.
10.
-TheLNRC-said5there was'no danger to the public, but would investigate why-.NU took over.an hour after power was restored to
= operate the cooling system-in the pool.
11.
On August 5, thirty days atter the event. NU filed their report,- LER 92-012-00,- with NRC.
But the document is unavailable tenus at this-time because of delays in getting-it microtiched.
The.May-1986 safety analysis report referenced the use of Shutdown Co'oling System (SDC) Operating P::cedure UP2310-that twas utill:ed b y. - t h + cont r o l. room in the-July 6th event.
This Shutdown Cooling System is needed as backup tot the pool's-forced' cooling system because the thermal load of the pool is increased by the 1986 rerack without increasing the volume of coolant water or the capacity 1of the pools ecoling pumps.
BecauseftF9Jallowable number-of-assemblies to be stored has been increases over thel years from 301 assemblies to 1965 assemblies, it is r.nticipated that - the cooling needs of the pool can not be met by the forced cooling system as-designed.
The shutdown coolant system-is needed not just.as backup should the pool cooling fail, but as augmentation of the operating pool cooling system-whensthe thermal load of the pool is as high as the rerack will allow.- Times to bolloff without forced cooling are-calculated as 9 3/4 hours with a recent refuel and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with an emergency full-core offload.
The worst case mentioned in the 1986 license safety analysis for bulloff is:an emergency full-core offload into a pool at capacity.. This-is noted to reach ~bolloff in-A hours.
Yet-it is
. the ' ref ue lL senar io-with its 9'3/4 hours to-boiloff t ha t -- i s used in.the-safety / analysis.
Even' though bolloft is1 considered possible, a full-boiloff is not ana ed.
The examples of-10 feet and-1.4 feet of water left over he1 fuel' assemblies is-not indicative of a full boiloff-senarao.
It-is not clear if the 9-3/4 hour-time given for a bolloff is.the time it takes to boil off only 1/2 of the water i n the pool.to leave 10 feet over the fuel, or to start it boiling.
.oritoiboil.ott all water.
Also it may-be that the time to reach 10 feet reference,(approximate 1/2 of a full bolloff) was not 3/4-hours'but-was halffof that time or 4-7/8 hours.
Also they do not make use11n their safety analysis using 1.4 feet i'
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' i 2CMN? Contentions regardin'g MiIIstone12'- FINAL VERSION PAGE-7
-over theifu'el-assemblies with the 4 hourIbolloff time when
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predictingLthe: environmental; impact'of-the bolloff-situation with
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the loss.of_ spent _ fuel cooling and in the case ofLthe 1,4 feet i
. elevation-the shutdown coolant system _is considered to be available_for pool cooling.
We need'to-know current-thermal loud of the pool so we can ascertain the time to bolloff and the risk of bolloff with the present-load in.the-pool under the new design.-
It i s ; conf us i ng - and.- seems deceptive to have presented for i
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environmental analysis of. radiation releases a bolloff that is not complete with 10 feet of water left over the assemblies after j
an undisclosed' period of time alter tho torced_ cooling system
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-talls.as-the worst-case when they present at the same time full 1
-boitoti figures.
- END OF' ACCIDENT SCENARIOS **
LContinuation-of Contention St.
LUnder1the new;designL(amendment #158)- Region 2 (renamed C) )Lis
- filled-with fuel' assemblies and the old Region _1
( _new ~ Regions A
_and B -, )--storag( limitations allow
-no room for another full-core-offload.
Resection B of Region 1 is licensed under-#158 to accept new_ fuel only.
It will:be' filled with new fuel at the t i m e'- o f refueling in September.or October ~ of 1992.
- Resection A of region 1-is1 currently _ filled with the full-core offload while steam generator ~ replacement is ongolig.
Also, since-only bulk temperatures are reported, we do not know
-it-a localized bolloff_in Region A where the^ful1-core i s:- p l aced, was considered a possibility during the'2-1/3. hour force,d cooling stopage-and coolant.waterEloss.of July 6.
Our concerns:ab'out criticality-continue to exist'because we are'
-uncertain of theLextent of erosion of boron from the Boroflex panels,' the accuracy or availability of-Bosoflex benchmarking-upon which rest the modeling for the multiplication factor
- ( K e f f ) ',- and.the-Linherent uncertainties'in the mathematical modelinE used.
When the-Keff was found to be too high to meet NRC safety
-standards,. It seemed that attention was given only to the safe placement of new.tuel, and the calculation of-Keff was readjusted to-allow 1 space-in the pool for; safe placement of the t
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1 CCliN - Cont e n t i on s regarding Miilstone-2 FINAL VERSION - PAGE 6 new fuel only.
Keff may-not have been calculated for Region icin its entirety.
With a full. core-or.tload in the resection called
. A,-the pool can be at or_ approaching a dangerous ieveI resulting in not only-r Keft greater than 95, but a_Keft greater than 1.
.T h i s means that we may be in immediate danger-from a. criticality
- and;a full boiloff;at Millstone 2 because-of Amendment #158.
Therefore we - f eel: justified in asking for an immediate stay to
- prevent'further use ot1that pool until it can'be made evident that.no immediate da i, g e r exists.
Since there are no monitors in
. the pool so that a situation can be seen to be developing that would necessitate'the movement of the fuel, we ask that monitors be immediately placed-in the pool to allow information on the existing Keff in the pool.
CONTENTION 4:
Immediate action is needed to stcp NU from
, contaminating the new steam generators until our concerns-for the-tafe stnrage ofEthe spent and new fuel is addressed.
Amendment # 158 allows for the continued use of the pool without regard to the added cost of removal of the contaminated new steam generator system which this license in affect permits.
NU asked in their Apri.l.16th applicacion tor.their request to be expedited because of their need to offload the core-to begin the
- steam; generator' replacement. The cost of this reple7ement is over 190 million dollars.
-lf in fact this amendment does not fully address the safe storage of spent and new fuel, NU may need to provide other-means of
'torage;for;1theLwastescurrently in the pool.
If the plant is to-s
=
continue operating, provisions must be made for waste generated during,the lifetime of the plant.
This license assumes that the waste generated-in the next.2 cycles can-be safely accommodated.
Beginning with.the refuel cycle'that'will start with renewed operation of the reactor,.NU looses full-core offload capabilities which they claim is tneir corporate and engineering-policy to maintain.
Elf-in fact the waste can no longer be stored in the pool safely, the ratepayers and stockholders need'to be financially able to carry the cost of-providing safe storage.
.Their choices should not.be. unfairly limited by failure of oversight from the NRC.
-9
-In earl'y September.1992 NU expects to be able to use refuel water i.
1-CCNN Contentions.regarding MILilstone FINAL VERSION PAGE-9 which is_ radioactive to. test the new steam generators.
This will contaminate them.
Ifffurther-production of spent fuel created by the operation of Millstone 2 is considered economically and environmentally
-unsound because of-the cost to safely store this fuel onsite, then-NU will need to treat-its $190,000,000- dollar steam generator _ system investment as low-level waste if they are allowed:to-test:it with radioactive water.
Because we ca nno t tur sure of what added costs will be arising from the criticality errors _that have recently surfaced, it is unfair-to-allow-NU to contaminate an otherwise good piece of 7
equipment.
If the_ cost of-safely. storing the fuel that Millstone 2 has generated and will' generate is not considered economically or
. environmentally-feasible by the ratepayers, stockholders. and state regulatory agencies,_that; decision should not saddle the ratepayers., stockholders and taxpayers with unusable and unsalable contaminated steam generators.
Nor with the cost of-disposing of them as; low-level waste.
They should not be denied the option of selling the_ steam generators to assist them financially _in providing safe storage of the_ current inventory of spent fuel and any other needs such as decommissioning costs-that would arise.in that position.
For the health ~and safety of the people, the protection of the environment, and'the economic liability of the ratepayers and stockholders, we contend that-immediate action should be taken by the NRC, since it is under.NRC amendment # 158 that NU justifies continued operations.
'Until our safety concerns are addressed, most importantly those involving'the use of-the " neutron-flux-trap" principle as practiced at Millstone 2, we do-not know-that storage in the spent fuel is safe.
- -BACKGROU.iD-****
=Theffollowing is a brief summary of NRC and other actions that we-feel.are relevant to the amendments-and actions we are contesting.
The Millstone !! power plant is a pressuriced Combustion Engineering reactor.
Engineering and construction was performed
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-CCMN Contentions regarding Millstone 2 - FINAL VERSION - PAGE 10 by-Becthel E n g i n e e r i r.g - C o r po r a t i o n.
The Turbine _was supplied by General-Electric Corporation and is capable of producing 870-megawatts?Of power' net.
- l 1975l Millstone-unit-2 begins operation, the spent fuel pool storage capacity _is 301 spent fuel assemblies-(about
- 1. 3 full cores).
1976 Spent fuel = processing plants will not be available in near future.
-discharged fuel is filling the pool.
A capacity expansion of the-pool-is needed to support _the engineering practice and NU corporate policy of reserving storage space in the spent fuel pool to receive an entire. discharged reactor core
(" full-core-offload")
should it become necessary due to-operational considerations.
1977 Amendment #109 all'ows reracking in Millstone 2 pool and_ increases the storage capacity to 667--spent fuel assemblies.
The storage locations.or " cells" now have a center to center spacing of 12.19 inches.
1982 Nuclear Waste Policy Act requires fuel owners to provide on-site spent' fuel storage until a~ government repository is available.
1985-After the sixth offloading-of 1/3rd of the reactor core fuel (cycle-6 refuel), 'the pool no longer has-space for a " full-core-offload".
-A full-core offload contains 217 assemblies.
1986 NU-states in their fuel consolidation application that " current circumstances in-the'back-end of the nuclear fuel cycle make it
- necessaryJthat fuel owners establish and: implement a plan for "ilfe-of-reactor-storage" of' spent fuel".
NU begins under amendment #117 to utilize a region strategy with a two-region design,_ increasing storage to 1112 unconsolidated fuel assemblies.--
RegionL1 contain's the high enrichment core-offload assemblies.
'The-rack design-employs the use of-borated neutron absorber material ~-(Boroflex)-as the " neutron flux trap."
The.Boroflex
-poisoned-fuel racks allows-'for 384 sterage cells to store 384 assemblies, with a nominal center to cente.-_ spacing of 9.8 e
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-CCNN-Contentions---regarding Millstone 2 -- FINAL-VERSION - PAGE 11 inchec, and 4 out'of 4-pattern.
- Region _2 spent' fuel rack design is now based on criticality _
acceptance criteria allowing credit for reactivity depletion in the spent fuel.
This region is1 reserved for fuel with 85%
design burnup-and allows 962 storage cells to be used in a 3 out of 4 pattern, with the empty blocked cell acting as a-
" neutron-flux trap."
These cells have a center to-center spacing-of 9.O. inches and'can store 728 unconsol.idated fuel-assemblies, in a 3 out of 4 pattern with the unused blocked cell-serving as a " neutron flux trap."
Before~the 1986 acceptance of spent fuel pool regionalization.- the physics criteria for-fuel stored in-the spent fuel pool had been defined.by the maximum unirradiated. initial enrichment of the fuel.
1987 August 11.
1987,- Northeast Utilities (NU) states that they reviewed the hot consolidation process as demonstrated.by the program gs,erically and determined the project safe and technically-acceptable.
They-state that the process and associated-risks and_ accident analyses are essentially the same regardless-of the scope of consolidation.
' NRC amendment s 117-approves the storage of consolidated fuel in cells of Region 1 and Region.2 and permits the use of Region 2 blocked cells for consolidated fuel allowing-1346 cells for storage.
1277 cells may contain consolidateo fuel (cans) and each can will contain material from two fuel assemblies (2:1).
~The assemblies to be.used in the consolidation process need to_be out of the reactor for at least five years and have undergone 85%
= burnup.-
The_ waste-from the consolidation process (skeletons) will be compacted ~into waste consolidation cans and treated as
- Class-C+ radioactive waste.
With storage restrictions imposed by the need to avoid criticality through consideration of neutron-flux trap material and storage configuration, and_with thermal load. restrictions imposed by-the pool _ cooling system, the allowable storage capacity of'the spent fuel is t. -1965 Lassemblies as ' f ol lows r 10n" spare cells" for' damaged fuel 362: cells with fuel assembliesLless than 5 years decay 688 cells with consolidated fuel.from 1376 assemblies 217 empty cells in region i for full-core-offload j
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~- -.
CCNN. Contentions regarding Millstone 2 - FINAL VERSION - PAGE 12 1277 total. cells.at capacity with 1965 fuel asseab!!es 1988-NRC issues Amendment #128 which deletes the footnote that had
- limited; storage of consolidated fuel to five consolidated Leanisters.
It also requires'NU to request approval to use temporary Spent fuel storage racks for long term storage.
Temporary spent fuel storage racks-are utilized during the consolidation process and are emptied when a consolidation "run" is completed.
1991-NU requests relief from compliance with 10 CFR 20.74a at their four Connecticut nuclear power plants to remove requirements for criticality monitoring in the spent fuel pools.
Other applications follow to remove from Technical Specifications
. references to the criticality monitors.
1992 February 14.NU notifies the NRC that design errors had been found in=the-spent fuel reracked area which contains boroflex panels.
This error was found by an independent contractor who was hired to do; blackness testing.on the Boroflex.
February 28 -_-Aseea, Brown, Boveri (ABB), formerly Combustion Engineering who was-the designer of the pool rerack. notifies the NRC of their explanation.for the discrepancy noted by independent contractor Holtec,. Inc., of-errors in the spent-fuel pool criticality calculations. This discrepancy puts Millstone 11 pool out of compliance since Keff is now calculated to be over
.95.
April NU applies for a resection of Millstone Il pool to allow a section just for new fuel.
This in effect reduces the area L
available"for the' freshly offloaded spent-fuel.
l' TApril 24 - NRC issues Amendment #67 for Millstone 3 removal of references to-criticality monitors in spent fuel pool.
May'20 NRC issues Amendment #157,for Millstone - 2 permitting NU not to have criticality monitors in the spent fuel pools.
April 28 - the Federal Register. notices the NRC' decision that redesign of-the Millstone'2 pool entails "No Significant Risk."
l
=May 28 - CCHN asks NRC to delay issuing the amendment to give time tol verify.the calculations upon which the safety of the redesign p
depends and to insure that the risk of criticality is in f act
~
=CCMN Contentions regarding Millstone-2 -1 FINAL VERSION - PAGE 13-
-decreased-byfthe amendment'rather than inadvertently-increased.-
This is denied by= John Stoltz, NRC projects director.
Requests for hearing and intervention were~ submitted by Earth"ision
-(Patricia Nowicki;, Mary _ Ellen Marucci (CCMN), and - M i c ha e l -- P r a y -
-(CCMN).
June 3-certificate of compliance issued for shipment of radioactive steam generators from Millstone 2.
June 4 NRC issues Amendment # 158 allowing the redesign.
July _3 - the full-core-offload is put in Region A of the pool as resectioned by amendment # 158.
There is 40% less space for spent tuel than what was available prior to the resection amendment #
-158.
July 6 - Power is lost and the pool forced cooling system stops operating.-see-LER 92-012-00 issued August 5.
Also, see our notes under-Acci-dent Scenarios in this paper.
July CCMN and other ci tizens :neet with NU and are-promised by NU within four' days the-calculations that NU. ABB-CE, and Holtec-
-have-'done - to-support amendment #158.
-CCHN also requests NU ta:
1.
place: criticality monitors in the pool.
2.'make~public daily their current releases of radioactivity to the environment, 3.
Provide Connecticut Department ef Environm,ntal Protection, Data Analysis Division, with online information from the two weather towers at the Connecticut nuc' lear power plant sites.
4 Provide information that will help determine the ra.dioactive inventory of the Millstone 2-spent - fuel pool-for the use of CT: Department of Health Services and-others who need to assess the health effects from a Spent fuel pool accident.
Sue CCMN letter July 22, 1992, and NU letter August 7, 1992.
1J u l y_ '29 - -- the ~ A tomi c Saf ety and Liccinsing Board Panel gives petitioners August 14 - deadline to file supplemental amendments to
-petitions to intervene to include contentions.
~
LAugust 5 - Thirty days after July 6 loss of cooling event in spent fuel poolfof Millstone 11, NU files LER 92-012-00, it is not available as of August 21 in NRC document rooms-because of delays
CCNN Contentions 1regarding Millstone 2-FINAL VERSION - pAGE 14 in)microfiching by~NRC.
- asee Accident'Senario. Event of JULY 6,1992 August ^7 NU reneges on releasing the calculations to CCMN and-claims - that the calculations NU and ABB-CE did are not relevant to'the-license amendment.
NU claims Holtec calculations are the basis for their license amendment and claim Holtec's quality assurance program did the-verification.
NU releases some Benchmarking information that is-incomplete with references to-inhouse documentation tnat NU may consider as proprietary and has not sent.
9 NU provides information of radioactive content of one 85% burnup assembly from which an estimate of the radioactive content of the pool can be calculated.
NU refuses to make available real time data from their weather
-towers and refuses to notify the public of planned releases
. claiming that what is legally required is all they will do.
NU will not address evacuation plans other than what their accident sensrio of one completely ruptured assembly under a pool full of water will require (nothing) and-thereby-imply their unwillingness to revisit the worst case accident scenarios of the
-SFpito' include criticality and enough water loss to expose the
- tuel.
-NU claims that calculations done by them and ABB are not relevant to the license amendment and are refusing to release them to CCMN. NU claims that'the The Holtec-calculations are the basis for-the license amendment and claims that Holtec's quality assurance program did the relevant verification.
August CCMN cubmits contentions with expert testimony to be
-submitted by August 24 August 141-an1 extension is granted to CCMN to submit contentions by August 24, 1992.
CCMN to show concerns are real and good causeLexists to suspect that amendment #158 not only may not' improve-safety margins enough to bring the pool up to NRC standards, but may in-fact-increase risk and consequences of a spent' fuel pool accident.
' Au gus t 19 --CCMN receives a phone call from Judge Ivan Smith of the'NRC's Atomic Safety and Licensing Board panel requesting that e
~
t MCCMN Contentions'regarding_ Millstone.-2 -1 FINAL VERSION - PAGE 15
.:al_l: people and. organizations that-are represented by CCMN-have
'their ma teria l s -submi t ted - not directly to_his panel but through-
- CCNN to=the NRC. -Also; CCMN shouldRelarity who is represented by them.
$ August-21;-LDr. Stanley-Turner _-of Holtec claims intormation on the inhouse runs and calculations done for'the Millstone 2 pool-redesign are. proprietary.. He states they were made'available-to.
Professor Vernetson.' University'of Florida, who checked the leti:
calculations for HOLTEC.
August 24 CCMN submits supplement to contentions and expri t testimony of.Dr. Gordon Thompson and Dr. Mich'o L a l: u.
End o f Bacl: g r eiund Summary a nti i nars d I c. ? + n e e d n Our contentions, submitted on August 14.and s u-temented with
-i J
supporting _ expert documentation in and attaches to this
. document dated-August 24 show our. concerns f; cut safety a r e ~ r ea l'.. a nd there-is good reason to suspect Amendment.#158 doesinot meet 1NRC safety criteria and-that the redesign it allows: may _have-increased risk significantly placing us now in -immediate danger.
Because welbe'lieve we may be-in_ imminent danger, we request
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the following relief:
Amendment-#157 needs to be' invalidated or amended, ICriticalityfmonitors are needed in the1 pool.NOW to give us
~
some: warning thatywill allow enough-time to take needed action to prevent;an inadver tent criticality.
Amendment.#158 needs-full review and public ' hearings in Connecticut.
Action-is needed before' October to stay the movement.of new
. fuel 11nto the pool;becauce of unresolved criticality issues a f f ec t i n g __.the safety of people---in the Northeast.
1-The useLof radioactive water in September to test the new steam-generators.must be stopped for.both safety and economic reasons -
_ Action is needed in September to stop the radioactive y
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... ~ _ _ _ _,
4' fCCHN Contentions regarding Hillstone 2 - FINAL VERSION - PAGE 16 contamination-ot the new steam generators by NU using radioactive water in terting them.
Unwarranted production of-radioactive waste-should neither be-encouraged nor permitted by public_-utility regulators or by nuclear regulators without public-participation in-these decisions affecting their health, safety'and economy.
Drs. Gordon: Thompson and Michio Kaku are sending notarized copies-of their affidavits by separate mail to the NRC panel.
They taxed CCMN copies of their testimony which we submit at this time in support of our contentions.
- This supplement to contentions with supporting expert testimony will be mailcd first class to those. people on the attached service list.
We: hope this matter before.your panel gets the time a-attention it needs to assure the safety and well being of the people o f. this area and we look forward to your cooperation in this matter.
We anticipate that'a hearing will be' held.soon and that you will
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expedite.our' requests for information and necessary action.
Sincerely,
'Y&y hh Mary Ellen Marucci, coordinator.
-Co-operative _ Citizen's Monitoring Network,ine.
- O r
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UNITED STATES OF AMERICA 3
NUCLEAR REGULATORY COMMISSION
'92 SEP 14 p4 :12 in the Matter of n.
y'~e.
e 50-5$Y'Lk,,*4i O
NORTHEAST NUCLEAR ENERGY COMPANY Occxet No.(s)
(Millstone Nuclear Power Station, Uni 1. No. 2)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Final Version CCMN LTR 8-24-92 have been served upon the following persons by U.S. mail, first class, except as otherwise noted and in accorcance with the reoutrements of 10 CFR Sec. 2,712.
Office of Commission Appellate Administrative Judge Adjudication Ivan W. Smith. Chairman U.S. Nuclear Regulatory Commission Atomic Safety ano Licensing Board Wasnington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Administrative Judge Charles N. Kelber Jerry R. Klins Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Commission Wasnington, DC 20555 Wasnington. DC 20555 Edwir J. Reis, Eso.
John T. Hull, Esq.
Ricnarc M. Kacich
_I Office of the General Counsel Director, Nuclear Licensing U.S. Nuclear ~tegulatory Commission Northeast Utilities Wasnington, DC 20555 P. O. Box 270 Hartford, CT 06101 Patricia R. nowicki Nicholas S. Reynolds, Eso.
Associate Director John A. MacEvoy, Eso.
EARTHVISION, Inc.
Winston i Strawn 42 Highland Drive 1400 L Street. N.W.
South Windsor, CT 06074 Was>.ington, DC 20005
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