ML20128D813

Informs of Admitted Minnesota Pollution Control Agency Contentions

ML20128D813
Person / Time
Site:	Monticello
Issue date:	06/13/1974
From:	Lewis S US ATOMIC ENERGY COMMISSION (AEC)
To:	Bevan R, James Shea US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20128D811	List: ML20128D808 ML20128D813
References
NUDOCS 9212070393
Download: ML20128D813 (7)

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Note to Roby Bevan Jim Shea/

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i Dy vWtue of the Licensing Bo^ards 6rder of 'May -22,- 1974,- and counsel for MPCA's verbal communication with me. it is now clear which (1PCA ith respect to W

contentions 11 ave been admitted in this proceeding.

the joint MECCA--Gadler contentions, it is not yet clear whether counsel will file the necessary affidavits and rewrite presently objec-tionable contentions with the requisite specificity and basis.

By this note, therefore, I am informing you of the admitted MPCA conten-tions.

As soon as the matter of admission of ttie MECCA--Gadler con-tentions is settled, I will so inform.you.

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HPCA COMTENT10iis A miTTED

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Contention II-O_.

j The section in the FES on gaseous wastes (pp. III-10 through III-18) is inadequate in these ways:

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- (.1 ) There is insufficient background and justification for the conclusion that 90 percent of the radiofodine will be re-h-

moved in the steau jet condenser.

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(2) No c'onsideration has been given to possible releases of radioactive gaseous' materials from the upper part of the tur-bine building.

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Contention II-18.

On p.111-20 of-the FES.the following statement is made:

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' Presently, all liquid wastes generated during normal operation _are being returned to the plant for reuse.

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In'our evaluation, considering expected operational occurrences and equipment availability, we assumed,

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that 10 percent of the water processed through the nixed-b?d daminerCine ulll be released frca the plant each., ear.

lleither the FES nor other documents prepared by AEC staff members in this matter' provide a justification for the use of this " assumed" figure.

In light of the operating experience at 11onticello (two years:uith zero liquid. release), the figure is_i_naccurate and un-warranted; Either the-justification ~for use-of this figure raust be developed, or a more accurate figure i..ost be chosen.

j Contention ~ 11-23.

Since the possibility of a fish kill due to sudden thermal shock is greatest in the discharge canal, the possibility of screen-ing off the canal to the movement of large fish should be explored.

Contention'11-24 (Combining A.6).

Because no terrestrial ecological study has been made at the 1

lionticello facility, it is impossible to determine the plant's 4

biological impact, including but not limited to its impact on any rare or endangered species found at the site.

(See FES 11-15 --

9 11-17.)

The applicant should be required to make a terrestrial study in order to determine the impact on the biological comuni-j ties involved.

Contention 11-26.

The.FES is inadequate in that it contains no discussion of-the following alternatives to the radwaste treatment system proposed by.the Applicant:

(1)

Operation of the off-gas treatment system on a full-time basis.

(2) llold-up times for gaseous effluent released from the main condenser air ejector system greater than those provided by the-proposed of f-gas treatment system. -

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(3)

Particulata and charcoal filtration for all secondary sources.

(4)

Cryogenic removal system for longer-lived noble gases.

i (5)

Clean steam for the turbine gland seals.

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':_:zam.1.iquid.re.le~ase. :perating.and_ treatment modes to achieve

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Facility for loading liquid waste into trucks for treat-ment e1sewhere, should the present zero liquid release mode prove ' unfeasible.

(8) Addition of a wiped-film evaporator system for tise on liquid effluents, should the present zero liquid release mode prove unfeasible. -

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Contention 11-27.

The discussion of direct ' shine doses on page XIII-25 of the i

FES is inadequate.

The shine doses must be measured and only then can a determination be made as to whether they are as low as practicable.

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Contention 11-33.

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AEC's evaluation of the probabilities of Class 9 accidents is deficient in the following ways:

(1)

Present analysis is too general, with specific analysis aimed only at loss-of-coolant accidents.

Specific analyses should be: developed, covering other kinds of possible Class 9 accidents, including but not limited to:

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major failures of the reactor pressure vessel, and i

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failure to scram incidents with major consequences.

Such analyses should make particular reference to the type of reactor involved and other specific characteristics of the plant in question.

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4-(2)

Present analysis, such as that presented by Edson Case in the Prairi2 Is1ind evidentiary hearinm is not really an analysis of

• probabili ty," in a s ta tis tical sense, it is not a " calculation" of the likelihood of such accidents, but a judgment.

Further statistical analysis should be undertaken and any " judgmental" evaluations should be affirmatively shown to be justified by appli-cable experf eifce and experimentation.

(3)

The present analysis only provides a design objective or

" aiming point" accident probability.

Ilhat is called for in addition is an indication of what probabilities carl be reasonably assured based on operative experience.

Becauhe of these inadequacies, further analyses must be made and the environmental effects of Class 9 accident at lionticello should be evaluated.

Furthermore, the adequacy of the erhergency plan to cope with an accident of this magnitude should be explored.

Contention 11-34.

Both the FES and the APPLICATICli fail to demonstrate that the

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standards for radioactive emissions set forth in 35 Federal Register 18385,.10 C.F.R. 5 20.1(c) are r.et.-

The standard set therein is that radioactive exposures and effluent releases must be maintained "as far below the limits specified in' this part as practicable."

The technical specifications for the pennanent operating license should require the use of the off-gas treatment system on a full-time basis and should also require the present zero liquid release mode of operation of the liquid radioactive waste system.

Only in this way can radioactive exposures and effluent releases be said to be "as low as practicable."

glTEllTIOlS 0!18X8 FUEL B.1 FUEL DESIGri EVALUATION Atl0 PROOF TESTIllG l

lleither the Applicant nor the Staff has shown that sufficient i

design evaluation and proof testing has been. performed to assure l

the safe performance of the ilonticello facility using the 8 x C I

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I fuel assemblies.

Both have alluded generally to previous operating cad testing experiance with nuclea: r'u: tar fuel: of designs tnat differ in one or more important respects from the proposed 8 x 8 reload fuel, but it+is apparent that operating experience with fuel of the proposed type is extremely minimal.

Recent evidence of anomalous lightwater reactor fuel behavior dronstrates the imprud-ence of proceeding with comercial' reactor og < ration in the absence i

of thorough fuel design evaluation and proof testing.

1 B.2 QUALITY ASSUPAICC fleither the Applicant nor the Staff has addressed the critical issues of quality assurance in the information docketed in this natter.

In the absence of inspection of quality control' measures during fuel manufacture, there can be no reliable evaluation of whether the fuel will perforra as designed.

B.3 El1ERGEilCY CORE C00Lif1G The Applicant has failed to present experimental and analytical, information that shows the conformance of the facility (using 8 x 8 fuel assemblies) with General Design Critorion 35.

Further, the Applicant has. failed to establish conformance of the facility (using 8 x'8 fuel assemblies) with the Commission's

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Interin Policy Statement, and has not adequately assessed the effect of various pipe-break sizes and locations, as required by the Interim Policy Statement.

The Applicant has also failed to consider the effects of flod blockage in its assessment of energency core cooling system per-formance.

i B.4 plVIR0!if1EllTAL IllPACT STATEMEllT REQUIREllEllTS The proposed change in fuel design incorporates a new fuel-array geometry, redesigned uranium fuel pellets and u:,e of fully-annealed rather than cold-worked zircaloy cladding. These changes and their potential effect on plant safety margins may significantly 9

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de tar the i,: pct or tn3 Icnticella facility on the avircrment.

Routine emissions of radionuclides from the plant may vary from past performance depending on the integrity of the new fuel.

The cffect of new fuel on the radiological consequences of system tran-sients may also be considerable.

In light of the foregoing considerations, the proposed change in technical specif.ications for' the facility' represents a major-federal action with significant potential impact on the environ-1 raent, a circumstance in which an Environmental Impact Statement is mandated.

RESERVATIONS As these Contentions on the use of 8 x 8 fuel assemblies are in part based upon documents which will be superseded, modified or supplemented before or during the hearing, liPCA respectfully re-serves the right to modify, amend, add or delete Contentions based upon such new information.

This reservation is in addition to that encompassed by the agreement between t4PCA, Applicant and Staff and g

i discussed at page 2 of this filing..

Further, it specifically in-1924 4

cludes the right to add Contention based upon use of the proposed t

pressure Relief Trip valves, once the Staff Safety Evaluation on J 9g dd the p.r.t. valves is completed.

This reservation also includes, but 1

is not limited to, the issuance of ahy other Safety Evaluations and i

I any Draft and Final Environmental Impact Statements issued on the proposed changes as well as any other documents issued by AEC, the i

l Applicant, or the Advisory Committee on Reactor Safeguards -(ACRS).

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A few explanatory comments are in order.-

Insofar as contentions 11-26 and 11-34 raise the issue of the " health l

effects" aspects of exposure to low-level releases, the appropriate portions of the record in the prairie Island proceeding will be incor-porated into the record of this proceeding.

l Thz Board has. admitted contention 11-33 only insofar as 11PCA is challeng-ing the appropriateness of the Staff assertions of low probability of oc-currence of a Class 9 accident, including ATWS and pressure vessel l

1 rupture.

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' b The only significance of tha " reservation" by MPCA at the close of its 8 x 8 contentions is that the Staff, as part of the agreement whereby MPCA withdrew from the proceeding on the 8 x 8 amendment, agreed that

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MPCA could, after publication of a Staff safety evaluation on the prompt relief trip system, seek to raise issues related thereto.

4 Picase bear in mind the following dates:

1.

Last day for filing discovery requests, July 26.

Please j

transmit to me any input with respect to questions you want to ask MPCA by July 12.

2.

All answers to discovery requests are due no later than August 30, and earlier responses would be required depending on when a re-quest is filed.

Since I anticipate receiving discovery requests from MPCA, I will need your assistance, and that of TR and BUL, in responding.

3.

Written _ testimony _to be filed by October 1.

1 4.

Commencement of hearing on October 22.

e I will be in further contact with you.

In the meantime, I request that you circulate these contentions to the appropriate persons in TR and at BNL.

Please emphasize to them that I would like suggested dis-covery questions by July 12.

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Stephen H. Lewis cc: Joseph F. Scinto i

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