ML20126L537

Petition to Intervene in Proceeding & Request for Hearing

ML20126L537
Person / Time
Site:	Quad Cities
Issue date:	05/28/1981
From:	Bos M CITIZENS FOR SAFE ENERGY
To:	NRC COMMISSION (OCM)
References
NUDOCS 8106040429
Download: ML20126L537 (5)

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9.'O. - %)N 7, UN!0E0 3TATEJ OF AYERICA -

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IN THE MATTER OF CCKYONWEALTH

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EDI3CN OC. OUAO ^!!!E3 STATION, f

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Units i and 2 ) Docket Nos. 50-254 50-265 ,

Amendments to Facility j 9

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Operating License Nos. I

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b' PE!!"!ON FOR LEAVE TO INTERVENE

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The members of Citizens for Safe Energy (hereinaf ter CSE) hereby moves the United States Nuclear Regulatory Commission "Comnission") for leave to intervene with respect (hereinafter the of Commonwealth to the Commission's consideration of the request E71 son Company (hereinaf ter " Licensee") for a modification to the the Quad-Cities Nuclear C'enerating Station spent fuel storace pooi of issuances of amendments to the Units No. 1 and 2 and for concurrant Facility Operating . cense.

Citizens for S. fe Energy consists of 210 members wnich reside tne Ouad-Cities Cenerating 3tation.

in the area around CSI requests that the Commission grant ' hearing on this pro-C3E and ary other interested individuals posed amendnent and tnat dings.

and organizations be allowed to participate fully in such procee tne Commission prepare an Environmental CSE further reques ts that Impact Statement.

I ENERGY INTEREUT OF CIT!ZENJ FOR CAM in the . ic e ns e e 's

~ 03E members nave a substantial interest request in nati area in The Guad-Cities Nuclear U ta tion is located in the nhich we live, work, and own property.

i in the storage of additional radioactive I 35E has an interest 4uad-Cities site wnien may crea e a nazard to this spent fuel at the revision was not considered during The micennae's propoced license area.

licensind proceedings for tne ,uad-Cities Fiant nor was it con-ine (?SAR) for the Quad-Cities pidered in tne Final Cafety Analysis brort fuel Flant.

The proposed modification in the operation of the spent 50 l

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POOR QUAUTY PAGES 6, .1 0 6 0 o p 6

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e pool dif fers significantly from One me tnod cf operation treated in

ne PGAR for One <uad-Cities plant. "hus 01. nas an interest in a fu.ll examination of the proposed license revision to ensure that l public health ana safe ty will ce pro te c te d.

The technical information submittec by the licensee in support of its amendment request is proscrtly inadequate to assess all the effects of proposed action on the area, inaanuch as the Licensee's application and supporting documentation for modifification to the spent fuel storage pools does not indicate the ultimate effects of storing large amounts of spent fuel for lanc unde termined time periods .

Grant of the proposed amendment to expand spent fuel storage capacity would contradict existing NRC policy in that it would under-mine the effect of the developing 6enerie ::S regarding the permanent and preferred disposition of spent fuel.

,The amendment request and supporting documentation do not address all alternatives for managing the spent fuel problem in the short term.

The licensee nas not explored tne alternative of curtailing present output from the Quad-Oities *ta tion either in conjunction with energy conservation and pricing alternatives wnich would result in a redaction of demand or in conjunction with increasing the use of under utilized fossil fuel plants to meet c urre n t demand.

The licensee has made no showin,$ inat it will be firsncially capaole of meeting the cos ts of eventual disposal of the spent fiel wastes which it intends to s tore in the expanded spent fuel pool.

The licensee should be required to provide a fund or security

- to cover costs of waste disposal.

The licensee should be required to provide a fund for reimburse-ment ove r and above that which the Price Anderson Ac t allows in order to compensate area citizens wno may be arracted by a nuclear accident caused by the release of radiation from tne a pe n t fuel.

The !!censea anould be requir5"i 'o M mit cout avaluations for nand1irg; transportation, storage, disposal and permanent s urve illanc e of excess spent fuel.

The licensee snould clarify tne monitoring system that is used and its ran;e of sensitivity.

The amendment request byIthe Licencee does not adequately discussi The amount of radioactive ma terials om!* ted including a definition of ne gligi b le , tne procedure by which neglicacio amounts of racicactivity are quantified, me inods of de tec ting a locc of neutron material and swelling of s taini,as steel rods in n torae.a racts.

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The licensee snould also discuss procecures to monitor ground wa ter movemen t in tha vicini ty of th" plan t for innkare from spent fuel pool.

Tne application and supporting doc umentation inadequately discuss the ramifications of enanging the rack confiCura tions in a pool where damaged fuel is stored.

There nas been insufficient consideration of potential occupa-tional hacards to workers installing racks.

The licensee snould discuss the effects of damaged fuel on a pool containing addition fuel elements in compac ted racks.

Licensee should discuss possible hazards and credible accidents involving release of additional radiation, chemicals and/or solid objects suen as sections of cladding and fuel rods from the defective fuel ptored in the pool.

There has been insufficient consideration of the hazards from exposure to workers to increased radiation when workers perform routine maintenance and/or special functions necessary to contain excess radiation emanating from damaged spent fuel.

The application and supporting documentation inadequately discuss the Quality Assurance programs regarding the integrity of the compacted racks and fuel baskets prior to installation and use.

The application and supporting documentation inadequately discuss inspection procedures necessary to de tec t defec ts in the compacted racks and baskets.

P IS ER VAT!CNS As these contentions are in part based upon documents which may be superseded, modified, or supplemented before or during a hearing on this ma tter, CSE respec tfully reserves the right to modify, amend, add or delete contentions.

_, Fur the r ;S E asks tha t the Commission act upon its Fetition in expedient manr.ar and that tne Commission decide wnether to grant the relief requested in this Petition before any further consideration of or action on the L!censee's request for a license amendment concerning Juad-Ci ties Genera ting J ta tion, either by the S taff or the Commission, I

prior to the Commission's action on this Petition snall be considered a denial of tnis Fe ti tion and final agency ac tion subjec t to judicial raview. OJ e: further requents tnat it be nivan prompt notice of any ac tion taken by tne Commission or the Staff on the Licensee's request to amend its license concerning the expansion of npent fuel storage at l

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the Quad-Oities Nuclear Plant by contacting CSE either by telephone or telegram, on the day such action is taken.

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Respectfully submitted

= 1 Citizens for Safe Eneret BY d' 4 e - [ j %' - -

1 Marilyrd Bos , 1 secretary  ;

Citiz9ns for Safe Energy P.O. Box 23 ,

Hillsdale, II. 61257 l (309) 658-2559 1

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JNITED STATES OF AMERICA NUCLEAR REGUIATORY OCMMISSION IN THE FATTER OF C0YX0?MEAIifH )

EDISCN 00. QUAD-CIIIES SfA2 ION, j Units 1 and 2 )

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Amendments to Pacility Docket No. 50-26550-254 [ ,

Operating License No. g

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DPR-29 and DPR-30 ) h \,.

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(Increase Spent Puel Storage f b Capacity) 9F _,

-' CERTIFICATE OP SERVICE I, Marilyn Bos, hereby certify that I have this 28th w

day of May,1981 served copies of the foregoing Petition for Leave to Intervene on each of the following persons by depositing same in envelopes addressed to said persons, first class, postage prepaid, and depositing with the U.S. Postal Office at 108 Butzer St. Hillsdale, Illinois 61757 Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C . Docketing and Service Section Executive Legal Director United States Nuclear Regulator /

Comission Washington, D.C. 20555 Isham, Lincoln & Beale Counselors at Law One First Natl Plaza, 42nd Pl.

Chicago, II. 60603 l

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