ML20137Z113
| ML20137Z113 | |
| Person / Time | |
|---|---|
| Site: | 07200001, 07001308 |
| Issue date: | 12/04/1985 |
| From: | Quigg C ILLINOIS SAFE ENERGY ALLIANCE |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| CON-#485-444 SP, NUDOCS 8512110225 | |
| Download: ML20137Z113 (9) | |
Text
'
l l
1.S.E.A.
ILLINOIS SAFE ENERGY ALLIANCE 53 West Jackson Boulevard, Room 343
- Chicago, Illinois 60604 * (312) 663:1667 December 4,.z l985 Mr. Nunzio Falladino, Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Docket Nos. 70-1308, 72-I3P (10CFR 2.206)
Dear Mr. Falladino:
The purpose of this letter is to respectfully request that the Commissioners of the U.S. NRC review the Director's Decision to deny the Illinois 3afe Energy Alliance's request for a federal environmental impact statement for General Electric's Morris Operation (GEMO).
'le feel the decision was clearly erroneous and that there are numerous deficiencies in the Director's Decision.
Some of the specific deficiencies are briefly outlined and attached.
The main deficiency in the Director's Report is its disregard for changes in the scope and nature of GEM 0's Operation in recent years, signaling a change in the status quo of that Operation. There is a lack of recognition of the fact that GEM 0's spent fuel pools and one-million gallon capacity radioactive waste tanks are built on fractured bedrock over, and in close proximity to, prime drinking water aquifers for northeastern Illinois.
We believe the changes in the Morris Operation are of such magnitude as to require a federal site specific environmental impact statement under NEPA.
Briefly stated, these changes are:
1.
An increase in allowed spent fuel capacity from 100 metric tons of spent fuel in 1972 to 750 tons in 1977 2.
An increase in allowed burnup of spent fuel allowed at GEMO, going from very low burnup in the 1970s to burnups as high as 44,000 megawatt days per metric ton of uranium (M"d/MTU) in the 1980s.
3 An exponential increase in curies onsite from (the Petitioner's) estimated 670 million curies in 1980 to an estimated ten billion curies in 1990 after GEM 0's new contracts with Cooper, Nebraska; 3an Onofre, California and Monticello, Minnesota have been fulfilled.
851211D225_851204 PDR ADOCK 07001308 C
page two 3
(continued)
This estimate does not take burnup into consideration, thus minimizing the total number of curies involved.
Je recognize that this is just a rough calculation of GEM 0's curie content and that there are other factors to consider.
However, we think NRC Commissioners should take note of the magnitude of this issue, with so much radioactivity available for dispersal into prime drinking water aquifers--both now and in the future.
GEM 0's license in 1979 permitted 2 5 billion curies of fission products to be stored; more radioactivity than in some reactors.
Now it seems that GEMO may contain up to five times that amount of curies, certainly a quantity worthy of cautious treatment.
Public interest in GEMO is keen. The continued violation of NSFA by the NRC, in not providing an environmental impact statement on G2MO, deprives Illinois citizens of their rightful participation in and knowledge of the serious environmental impacts of GEMO.
Sincerely, GM/
-g Catherine Thiel Quigg Research Director Illinois Safe Energy Alliance (312/381-6695) cc:
James K. Asselstine Thomas M. Roberts Frederick M. Bernthal Lands 'J.
Zech
,,m,.
--,a
page three SPECIFIC DEFICIENCIES IN DIRECTOR's REPORT 1.
The NRC Staff asserts that Section 6 3 of the EIA (NUREG-0695) and 7 3 of the 3 3 discuss the hydrological monitoring program at GEM 0 and methods to control potential leaks.
I3EA Restonse:
The Petitioner has reviewed Section 6 3 of the EIA and finds that the hydrology of the GEMO site has been inadequately addressed therein for the following reasons:
Hydrology is concerned with undeground sources of water.
The EIA does not address the fact that a major drinking water aquifer for northeastern Illinois lies directly under GEMO.
The failure to specifically mention this importnat fact avoids the issue of potential groundwater contamination from GEMO spent fuel pool or radwaste tank leaks.
Only the potential for contamination of surface water, namely the Kankakee River, is mentioned.
The SER's discussion of sampling and monitoring practices, while of interest, adds nothing to our knowledge of vital hydrologic considerations at the GEMO site.
Monitoring will not impede the flow of radioactivity to underlying aquifers.
And, unfortunately, monitoring is not effective in detecting leaks when there are fractures and faults as exist at GEMO.
In describing this phenomenon, U.S. Geological Survey geologist George DeBuchananne has said: "If waste is moving through a crack, and you do not know how the cracks are interconnected, you can put in monitoring wells and completely miss the movement of the waste."
The GEMO site has a fracture system that can act like a pipeline carrying radioactive liwuid through the rocks to the aquifers under the plant.
A monitor could miss the movement of liquids flowing through a " pip aline" just a short distance away.
Thus, monitoring--while a necessary adjunct for discovery of surface water contamination--is inadequate for immediate j
determination of underlying aquifer contamination.
Another U.S. Geological Survey geologist, Dr. Eric L. Meyer, advised the U.S. Atomic Energy Commission in 1967 that a leak from GEM 0's spent fuel pools or liquid radioactive waste tanks could flow through the fractured rock beneath the plant to major drinking water reservoirs supplying drinking water to millions of residents in northeastern Illinois.
- le advised that monitoring of wells pumping the aquifers would not be effective in detecting leaks into the shale because the appearance of a contaminant would indicate
. c,
page four the leak had started decades earlier.
He said, "This, then, would mean a large mass of contaminant is enroute towards the aquifer and that over a period of centuries a large volume of the aquifer would be affected."
l-A. The NRC Staff claims that: "The potential for flooding was evaluated in Section 2.8 of the Sin."
ISEA RE3PONSE The Petitioner does not have access to the S3R as that document is presently unavailable at the regional NRC.
However, we have examined the S AR (NEDO-21326) in this matter and can find no substantive discussion of flooding.
Although the SAR reveals that GEMO was located only 5 feet above the maximum estimated flood of $25 feet in 1977, there is no discussion of the potential damage to GEMO and the surrounding area from a flood at or above the. estimated maximum flood elevation or how damages could be controlled or repaired.
Furthermore, we find it curious that the maximum flood elevation was estimated at 525 in 1972 and again in 1977 (NED0-2136).
Flood plain maps and flood heigh estimations tend to be outdated quickly i
since flood plain areas increase with construction and urbanization as have occurred near the GEMO site.
Thus, one would expect the GEMO l
estimated maximum flood to be higher now than in 1972, raising the question of whether flood data has been updated.
E.
Iha EC Staff asserts that the Petitioner errs in expecting environmental assessments (or appraisals) to contain geological and ecological data for determining potential adverse consequences from the operation of GEMO-- because environmental appraisals need only "make a convincing case that the impact is insignificant."
i l
1 ISEA ResDonse In using the term " environmental assessments", the Petitioner was speaking generically and including all environeental data produced thus far on GEMO, including its 1972 environmental impact l:n 0:
page five statement and safety analysis report, and all subsequent environmental
~
We find that the original 1972 GEMO EIS fails to provide appraisals.
relevant, quantified information on vegetation, small mammals, birds, It is fishes, insects, and other life forms, as required by NEPA.
impossible to adequately evaluate probable or adverse ecological effects of GEMO and irreversible commitments of local resources without baseline quantitative data to evaluate trends and effects.
Thus, the original SIS on GEMO does not conform with NEPA which requires consid-eration of mitigation for adverse environmental impacts.
Without an adequate data base, rational and relevant mitigation of adverse j
impacts of GEMO will not be possible in future years.
i Subsequent environmental appraisals have not addressed these deficiencies in the 1972 EI3.
The millions of people in Illinois who depend on the aquifers beneath GEMO for their drinking water are entitled to a complete environmental impact statement weighing all potential environmental effects and alternatives, assuring that the NRC has fully considered environmental effects and alternatives to GEMC and has incorporated all practical means to avoid or mitigate possible adverse environmental effects of the licensing of this facility--especially since such a study has never_ been performed for GEMC.
3 The :SC Staff states that dry storage of spent fuel would be prohibited under GEM 0's license renewal but that, pursuant to 10CFR 72 35, GEMC can conduct dry storage tests with spent fuel routinely received in dry storage casks at GEMO.
I3EA Response l
The Fetitioner has reviewed 100FR 72 35 and finds that this amendment allows licensees to perform tests and experiments without prior approval "unless it involves unreviewed safety questions, significant occupational exposure or a significant environmental impact."
This amendment further states that a proposed test shall be deemed to involve an unreviewed safety question "if a possibility 4
for accident or malfunction of a different type than any evaluated previously in the 3AR is created."
The Petitioner has reviewed the 1972 EI3 and 3AR for GEMO and fails to find an evaluation of criticality accidents which may occur due to the flooding of a dry storage area or, indeed, the evaluation of any type of dry storage accident; including the type of accident which occurred on May 2, 1980 at Battelle Columbus
page six 1
a In that dry fuel cask accident, uranium from the cask i
Labs.
producing a radioactive dust which contaminated oxidized rapidly, ding interiors and led.to radiation exposures above the cask and buil recommended levels. (See letter to Charles MacDonald, NRC division i
from Dr. Marvin Resnikoff, dated of fuel cycle and material safety 53, this type of dry storage Nov. 5, 1983. )
As of November 19 accident had not been incorporated into NRC safety analyses, computer codes.and environmental reports.
Thus, we have here a type of accident which has not been evaluated previously.
l 1
4.
The NRC Staff conteds tha t the 3IA, 3ection 3 3, specifically i
considers water use for high burnup fuel.
ISEA Resconse The Petitioner has reviewed the EIA, Section 3 3, and finds If the increased no specific reference to high burnup fuel.
water demands will be due to high burnup fuel, this should be so J
stated.
4-A. The NRC Staff contends that the SSR explicitly considers spent fuel with burnup of 44,000 megawatt days per metric tons of-uranium (MJd/MTU) and that GE's license for the Morris Operation explicitly prohibits storing spent fuel with higher burnup than this.
)
ISEA Response 1
The NRC Staff answer is not responsive to the concerns raised by Petitioner.
Until recently, standard (low) burnup fuel has been Thus, the NRC, by' allowing G5 to store-i
'26,000 to 33,000 Mwd /MTU.
spent fuel with 44,000 Udd/MTU. burnup, allows high burnup spent. fuel at'G3MO.
Spent fuel at GEMO in.1980 had an average burnup of only 15,500 mwd /MTU.
-The NRC Staff provides the Fetitioner with no response regarding the environmental impacts of high burnup spent fuel which will be stored'at GEMO.
High burnup fuel, with its greater quantities of long-lived fission products poses a much greater-problem in potential accident situations.
There is an exponential increase of transuranics, like plutonium, in high burnup fuel.' Americium and neutrons are i
decay products in high burnup fuel, which will increase worker 4
E m
e.
-.n m
, - - - - - - + -,,. -
,vm-,,,,,,--,-n e-w,,w-,
., - v
---e 4-
page seven exposure at GEM 0 and in transit. Additionally, the spent fuel's cladding may be partially degraded, thus making this type of spent fuel more vulnerable to corrosion, stress, cracking and degradation.
None of these points were addressed by the NRC Staff in its Report.
The accident consequences reported in NASH-1400 were based on low burnup fuel--only up to 26,000 UWd/MTU burnup.
There have been no NRC safety analyses or accident essessments based on higher burnup fuel, to our knowledge.
The NRC Staff may choose to equivocate by saying 44,000 Mid/MTU is not high burnup spent fuel, but rather intermediate burnup since fuel can go as high as 65,000 mwd /MTU.
Je would respond by saying that 44,000 Kid /MTU is three times higher burnup than GE is accustomed to receiving in the past and that the impact of this enormous heat and radioactivity increase at GEMO should be evaluated now.
We are also mindful of the fact that an NRC amendment to GEM 0's license, without public scrutiny, is all that will be required to allow GEMO to go beyond 44,000 M.ld/MTU burnup.
5 The NRC Staff contends that sabotage of spent fuel up to 44,000 Mid/MTU has been evaluated in the SER.
ISEA Response Since the Petitioner has no access to the SER at this time, she has reviewed the SIA for its discussion of sabotage of high burnup spent fuel.
Section 9 1 of the EIA reveals that " Sabotage through the use of high explosives could likely produce cask penetration."
There is no description of the burnup of the fuel in the cask involved or the consegunces of such a scenario.
The EIA states that although the consequences of such a scenario have been evaluated, " presently available information is not conclusives."
The Petitioner believes the public is entitled to conclusive ~information before more spent fuel is transported to GEMO and stored there indefinitely.
The NRC implies in its response that spent fuel with burnup of 44,000 mwd /MTU is not high burnup spent fuel.
We believe that fuel with this length of burnup qualifies as high burnup fuel today and should be so identified by the NRC, unless it has compelling arguments to the contrary.
More to the point of sabotage, GEM 0 will contain approximately 15,000 pounds of plutonium by the time it reaches its 750 ton capacity, enough plutonium to make hundreds of nuclear weapons.
pago eight 4
6.
The NRC Staff contends that even through GEMO has gone beyond its original contractual obligations, the scope of its operation has not changed.
The NRC 5taff implies that, therefore, an EI3 for GEMO would not be required under NSFA.
The NRC argues that NEPA does not require an EI3 be prepared when an action does not directly or indirectly bring about any change in the environmental status quo.
Furthermore, the NRC crgues the N3PA does not require the NRC to reconsider environmental decisions whenever new information becomes available, unless the new information would clearly mandate a change in result.
I3EA Rosconse GEMO has been converted from a reprocessing plant with a spent fuel pool for short term storage of low burnup spent fuel to a long ters storage facility for low, intermediate and high burnup spent fuel.
This represents a major change in operation and the environ-mental status quo.
In December 1971, before an EI3 and SAR for GEMO was completed, the NRC licensed GEMO to store up to 100 tons of spent -fuel for 5 years.
In December 1972, an EIS and 3 AR on GEM 0 was completed.
The NRC asserts that these documents consider both the safety and environmental impacts of fuel storage and reprocessing.
In 1975, the NRC changed GEMO's license to allow storage of 750 tons of spent fuel.
The I3EA finds that since the 1972 EIS was issued, the quantity and quality of spent fuel allowed storage at GEMO has drastically changed, as has the duration of storage.
The fact that GEMO has gone beyond its original contractual obligations is material.
In 1977, the Illinois Attorney General asked the NRC for an EIS on GEMO before granting GE's request to increase its spent fuel capacity to 1100 metric tons of spent fuel.
(GE subsequently withdrew its application.)
In denying the Attorney General's petition for an EIS, the NRC said: "The GE Morris Operation is primarily for servicing customers to whom GE has obligations under what were orginally reprocessing contracts. GE has further stated that the proposed expansion of Morris requested under the current amendment application has been primarily considered in light of interim storage requirements of certain of its reprocessing customers."
Thus, it is germane that GE is currently going beyond its original contractual obligations, even before its 750 tons capacity has been reached.
Even the NRC considered GE's contractual obligations germane in its 1977 denial to the State of Illinois.
We urge the NRC to review GEM 0's original contractual obligations so that GE is not permitted to evade the truth in future license applications to expand its spent fuel capacity, as it did in 1977 Resnectfull s bcitted, "
G
/
/
Catherine Thiel qui g
Nuclear Wastes Threaten Illinois Aquifer B Cetherine Thiel Quigg abandon plans to reprocess in 1974.
3 Over the next five years, the However. the NRC allowed GE to nation's largest shipments of spent store spent fuel in its pools. increas-nuclear fuel are destined for Gener-ing storage capacity from its origi-al Electric's Morris Operation in nal 100 tons to 750 tons in 1975.
Morris. Illinois some-55 miles The NRC issued GE a new license southwest of Chicago. More than on May 4,1982 as the nation's first 2.000 spent fuel assemblies from independent spent fuel storage in-Nebraska and Minnesota will be stallation, without a federal envi-sent to Morns for safekeeping (see ronmental impact statement -
Re: sources, spring 1985, page 1).
despite the known inadequacies of However. Morris is not a safe the site and legal challenges from j
site for the storage of highly radio-Illinois attorney general.
actis e nuclear waste. There has 1arge quantities of radioactive j
been little discussion of the one liquid wastes from the cleanup of aspect of the Morris site that should Morris' pools and spent fuel casks 1
rule it out forever as a place to keep -funneled to tw o huge under-spent fuel. It is the total unsuitabili-ground low level waste tanks -
ty of the site from the standpoint of pose the greatest immediate danger.
its geology and hydrology. Potential These one-million gallon capacity drinking water contamination is the tanks. built close to the aquifer.
biggest threat caused by these inad-contain spent resins with long-lived equacies.
radioactive elements such as cesi-The type of soil and rock, the um-137 which could render the local flood patterns and the close water unfit for generations.
proximity to underground water The existence of these low level supplies should have prevented the waste tanks and spent fuel pools at selection of Morris as a waste stor-Morris, in close proximity to major age site at the outset, especially lilinois drinking water supplies, sig-since this information was available nifies a breakdown in public health before the plant was constructed-protection. Now, with the largest In 1967, a U.S. Geological Sur-shipments of spent fuel in the his-vey geologist advised the U.S.
tory of the United States headed Atomic Energy Commission that a toward Morris from nuclear plants leak from Morris' spent fuel pools in Nebraska and Minnesota, this or liquid radioactive tanks could breakdown is even more apparent.
flow quickly through the fractured rock beneath the plant to major For more irtformation contact:
underground reservoirs supplying Illinois Safe Energy Council, 220 drinking water to millions of resi-South State Street, #1202, Chicago, dents in northeastern Illinois.
IL,60604, (312) 736-9041.
In his report to the AEC, Eric L Meyer warned that radioactive con-
^ ~ - ^
taminated water could flow through
~
faults, fractures and joints in the shale rock under the plant - reach-ing prime drinking water aquifers in a matter of decades. Dr. Meyer wrote: " Fluid leaks from the part of l
the building that extends into the shale probably would pass through the shale to the nearest fault or fracture zone" and "most of the flow would go down to the Galena Dolomite." The Galena Dolomite is an important aquifer that sup-plies drinking water to Joliet and l
northeastern
- Illinois, including l
parts of metropolitan Chicago.
l Disregarding Meyer's admoni-tions, General Electric began build-
^
ing a spent fuel reprocessing plant at Morris. Workers used dynamite to blast into the shale, creating even more cracks and fractures.in the brittle shale already riddled with ancient fault lines.
Serious technical problems with reprocessing systems caused GE to
_ _ _