ML20140C728
| ML20140C728 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/13/1984 |
| From: | Fowler L CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), LEGAL ENVIRONMENTAL ASSISTANCE FOUNDATION |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20140C724 | List: |
| References | |
| OL, NUDOCS 8406190424 | |
| Download: ML20140C728 (8) | |
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UNITED STATES OF AMERICA (F
00CKETED NUCLEAR REGULATORY COMISSION ustac BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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.In the Matter of
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GEORGIA POWER CO.
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Docket Nos. 50-424 and 50[425ihu & SEPV et al.
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(Vogtle Electric Generating Plant,
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Units 1 and 2)
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SECOND AMENDMENT TO SUPPLEMENT TO PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR A HEARING CPG-11 as Amended i
Applicant's failure to consider defects in the Vogtle steam generator system constitutes an undue risk to public health and safety in violation of 10 CFR 50.34(b), 50 Appendix A, 50 Appendix B.
West 5nghouse PWR steam generator tubes have shown evidence of corrosion-induced wastage, cracking, reduction in tube diameter, degradation due to bubble collapse water hansner and vibration-induced fatigue cracks.
Of primary concern is the capability of degraded tubes to maintain their integrity during j
nonnal operation and under accident conditions. NRC " Unresolved Safety Issues 4
Summary" August 20, 1982.
[ Applicant has provided an extensive description of its steam generato*s and rater chemistry program, presumably to address the admitted problems in d
other Westinghouse steam generators.
As acknowledged by the applicant, these problems include "the forms of tube degradation that have been experienced in other Westinghouse steam generators:
wastage,1ntergranular attack and cracking." However, in reference to the Model F steam generator to be used in VEGP, "Recent operating experience...has revealed areas on secondary surfaces where localized corrosion rates were significantly greater than the low general corrosion rate.
Both intergranular stress corrosion and tube-wall thinning were experienced in local areas, l
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wea environmental' conditions (water chemistry, sludge composition)." VEGP FSAR n
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-n: j5.4_.2-9. _These are exactly the types of serious problems that have been shown l
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......tm f.1;., to' exis@M other Westinghouse steam generators and admitted as a contention in aw
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Rockford League of Women Voters Intervenor, v. Commonwealth m
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&g Ediso61CohBryson Nuclear Power Station, Units 1 and 2, NSSS Westinghouse.
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wmA Noyrithstanding the above, the applicant contends that these serious N7f' '
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'lEE problems 34ia'ye been solved by a number of technical advances, the most important n
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As highlfixpT6sive' in pure fom) and ammonium hydroxide.
Successful AYT C
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fpf operatidnirguires maintenance of low concentrations of impurities in the steam
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generatorewater..." VEGP FSAR 5.4.2.9.
However, the details of how low these w
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concentrat_1ons must be, and.how they will be maintained, are not adequately
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address,gged3y;the applicant.iThe applicant expresses an apparent lack of q
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confidenceLin the AVT technology in the following, quoted from the above y
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ATV program should minimize the possibility for recurrance of G
1 Branular corrosion in localized area..."
is t mQ w "A" comprehensive program of steam generator inspections...should provide t foMetection of any degradation that might occur in the steam generator tuli 1@" + f Rf: Use of..'t.he.71anguage "should. minimize" and "should provide"' demonstrates ? W . -;%? .W e:. uncertainty.3 An adequate solution to this problem would inspire confidence x m gi 2+ .r that t ogram "will" eliminate the corrosion and "will" provide for detectionM degradation.] x:: t% i The applicant has not considered nor is sufficient technical infomation J L.. currently available to deal with a steam generator tube rupture accident u - .?',.. r J'1 .f.u. -m-e+.g b ,,,------w,y,,--,,mmn,- + e, a-m, w w-,. -,. e--ew
a.g m,- f k A uo. ;ea e e s. e. .faQ W," s e 9((]SGTR) [Such an accident at Plant Vogtle would have serious consequences ]l _ including core meltdown and severe danger to the public health and safety.] r m.. r 7" This was considered in a hypothetical study of the Borse11e Nuclear Power } Stationc NRC BN 83-151. The TMI-2 accident convinced Westinghouse to change i the ECCS actuation logic by eliminating the low pressurizer level trip, and
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this was implemented by licensees with Westinghouse plants [, of which the .sv j applicant is one]. A simulated accident at Borselle was calculated to actuate
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the ECCS which would probably produce "undesireable attendant problems, such a [' RCP trip [and containment isolation, which would make accident management more a:
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? difficult.7. Memo from D.J. Mattson, Director DSI, NRC to D. Eisenhut. Director N. . Y~L Division 3f' Licensing, NRC, September 26, 1983. As stated in the above memo c. 3 :;. z,g theNRCktafffeelsarevisionoftheECCSlogictothepre-TMIaccident 2c. - configuration "has the potential to improve management of SGTR events." m. nam-Howevirfthestaffcouldnotconcludewhetherthis"revisionwouldhavean ~ T y, overallgt,11ncreaseordecreaseinplantsafety." [ Clearly, unless this w mu problendstresolved, there will be an undue risk to the public health and y g safetylifjPlant Vogtle is allowed to operate.] M iG 2. =. a.m. 1 Amendmen6o~ CPG-2 is In(CPG'sAMENDMENTTOSUPPLEMENTFORLEAVETOINTERVENEANDREQUESTFOR q_ HEARING,3page 4, line 18, following the phrase "whether it will ever be 'used'."N1easeinsertasfollows: fMi whether:31%111 ever be "used." In Georgia Power's most recent Fuel Cost 3l% Recoveryproceedings,whereintheapplicantrequestedanincreaseinelectric rates toher allegedly higher fuel costs, several members of the Public cc Service Commission again raised questions concerning the need for Plant Vogtle
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(please see' Attachment 1).
R Amendment to CPG-3 In CPG's AMENDMENT TO SUPPLEMENT FOR LEAVE TO INTERVENE AND REQUES HEARING, page 7, following the paragraph which ends "whether the plant will ever be 'useful' as well as 'used.'", please insert the following: In Georgia Power's most recent Fuel Cost Recovery proceedings, wherein the applicant requested an increase in electric rates to cover allegedly higher fuel costs, several members of the Public Service Commission again raised questions concerning the prudence of the construction of Plant Vogtle and whether it will ever be included in the rate base (please see Attachment 1). On page 9, following the paragraph ending with " radioactive wastes due to the financial problems.", add the following paragraph: In an incident for which it was fined by the NRC, Georgia Power operators attempted to override safety systems at Plant Hatch due to financial considerations. This was acknowledged by the applicant's top nuclear engineer for operating reactors who stated before the Public Service Commission in hearings concerning a request for increased fuel cost recovery rates (June 6, 1984) that workers who attempted to override the safety systems were " conscientious" in their concern for saying fuel costs. At this writing, the transcript from that day of the PSC hearings is not yet available. a l I
y. w c,. w. . m-- .b. ] j.;& fi ATTACHMENT 1 x:
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- ~f-7At hearings which concluded June 6, the Georgia Public Service Commission L
considered an application by Georgia Power for higher fuel recovery. At this = ..w ^ writing, the transcript from the final day of hearings was not available; 7 ..n during that hearing, Comissioners Spinks and Pafford raised additional g, y, questions as to whether the construction of Plant Vogtle was prudent and .;w.. C needed. eat various times, all five members of the Georgia Public Service ~ Codissionhaveraisedsuchquestions. 1 IThe transcript from the first day of hearings (there were only two days o 4 q h heari5gs) is on file at the Public Service Comission. Relevant excerpts from 3 g tho,se; transcripts (which were not available prior to the prehearing conference c Wi.4 3c. follow:i 4 @ff. [ Conurissioner Bobby Pafford: I will give y'all credit for one thing, you saw it f wasn.'tsoo good a deal and you sold out a lot of it so I will give you credit 11, forfghat. (p. 25, lines 9-11, referring to sales of Plant Hatch) f ~ }Q; ^ d CommWsioner Pafford: ...you don't have to keep building plant if it is goin 1 to bE.true when you have already got more than you need. (p. 37, lines 22-24)g k and;1f@udon'tneedthem. (p. 38, lines 3-5) 7 .g;n qp. Comissioner Pafford: If and when Vogtle--since you are talking about the rate baseEif and when Vogtle goes into the rate base, how much would that increase yourhete base?. ~ AEEf._ The Witness (Romney Scott, Georgia Power): Increase the rate base or reserves? The_ rate base would go up-- -W e Commissioner Pafford: If it was allowed. p( (p. 38, lines 18-24; note the word "if") Q* i. Comis foner Pafford: If the people are enjoying the use of their electricity 2; now,hhey had better enjoy it a whole lot more when all of that money, if it ~ doessgo71n, on Vogtle goes in, because it is going to cost a pile more. (p. = 40, lines 9-12) ~ 'Tk= Comissioner Pafford: When can we expect consistent production out of Hatch? The Witness (Scott): I can't answer that, Mr. Pafford. [ i
~ r Comissi:ner (Ferd) Spinks: If you can't expect consistency cut of Hatch, th2 how can you expect it out of Plant Vogtle? The Witness: We expect consistency out of Hatch, Mr. Comissioner. Commissioner Spinks: But we are not getting it, how could we think we are going to get it out of Vogtle when we are not getting it out of Hatch? (p. 50, lines 13-23) Commissioner Pafford: Any way you can sell the rest of Hatch and Vogtle? Do you know of any way? (p. 63, lines 4-5) Comissioner Pafford: I want to ask the witness, do you think we can still attract industrial customers into Georgia when we had that three and a half billion dollars which will be almost doubling our current rate base, will they be able to come to Georgia and produce goods when we double our rate base just about? (p. 140, lines 20-25). Comissioner Pafford: Well, don't you imagine the industrial customers are F.articularly concerned about this development that is fixing to come up? The Witness: They are also very concerned about the availability of electric power. ; . i.44. Connissioner Pafford: And a lot of them are beginning to build their own plants because the companies are getting so high, they can build a plant cheaper than what they are buying it. You are aware of that too, aren't you? T-The Witness: I am aware of that. Comis f ner Pafford: Can't you inngine we might see more of that? The Widess: I think you can see more cogeneration in the future, yes. It is very possible. We are facing it all the time. We have some cogeneration on ~ the system right now and it is entirely conceivable that we will have considerably more. 7y (p.141, line 16 through p.142, line 7) Note: great deal of concern about the need for and prudence of Plant Vogtle was also expressed by the Comissioners at the second day of hearings. The r u g=c degree}f, concern should be indicated by the fact that this particular proceeding did not deal with Plant Vogtle, but only with current fuel costs. t c
~ a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 03$hhnfD U E ~ BEFORE THE ATOMIC SAFETY AND LICENSING BOARD N -In the Matter of ) M /g ) 38 c GEORGIA POWER CO., et al. ) Docket Nos. 50-4244k. .50-425 (Vogtle Electric Generating Plant, ) A Units 1 and 2) ) CERTIFICATE OF SERVICE This is to certify that copies of the foregoing Second Amendment to Supplement to Petition for Leave to Intervene and Request for Hearing were served by MCI Mail to members of the Atomic Safety and Licensing Board, by hand d delivery to Troutman, Sanders, Lockerman & Ashmore and by first class mail to the other parties this 13th day of June,1984, to all parties in this proceeding. [ signed] ~.:n 3.g Laurie Fowler for: Ep;; Legal Environmental Assistance Foundation L.1~ 1102 Healey Bldg./57 Forsyth St. NW 2 "- Atlanta, GA 30303 a' 404-688-3299 ~ Attorney for Petitioner Campaign for a Prosperous Georgia O \\ l
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g.f. m SERVICE LIST Morton B. Margulies, Chairman Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board Panel ~ U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris Docketing and Service Section Atomic Safety & Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington,' D.C. 20555 Washington, D.C. 20555 . l ': Mr. Gustave A. Linenberger Bernard M. Bordenick, esq. Atomic Safety & Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety & Licensing Board Panel Carol A. Stangler U.S. Nuclear Regulatory Commission 425 Euclid Terrace Washington, D.C. 20555 Atlanta, Georgia 30303 n Douglas CE Teper Dan Feig 1253 Lenox Circle 1130 Alta Avenue . Atlanta : Georgia 30306 Atlanta, Georgia 30307 Jeann bbhthouse George F. Trowbridge 507 Atlanta Avenue Ernest L. Blake, Jr. Atlanta,~ Georgia 30315 David R. Lewis a c r_ Shaw, Pittman, Potts & Trowbridge James ErrJoiner 1800 M Street, N.W. SusmerTC.MRosenberg Washington, D.C. 20036 Troutman,r. Sanders, Lockennan & Ashmore 127 Peachtree Street, N.E. Ruble A. Thomas Atlanta'iGeorgia 30303 Southern Company Services, Inc. nr1 P. O. Box 2625 jifjj Birmingham, Alt 5ama 35202 3 U. ~:: i 4 n .e '52 w;1: ,a l f f .-_.}}