ML20148D455
| ML20148D455 | |
| Person / Time | |
|---|---|
| Site: | 07002909 |
| Issue date: | 10/01/1980 |
| From: | Allred D AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20148D453 | List: |
| References | |
| NUDOCS 8010080285 | |
| Download: ML20148D455 (27) | |
Text
10/1/80-O UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION
~~I bf T-I
+ k' 4$$./
~1 BEFORE THE AT0mIC SAFETY A ND L I CE NS I NG BOARD
,f
" cs" In the Matter of N'N
//s'/
s APPLICATION OF WESTINGHOUSE ELECTRIC CORPORATION FOR A SPECIAL NUCLEAR i.1ATERIAL LICENSE FOR THE ALABAMA Docket No. 70-2909 NUCLEAR FUEL FABRICATION PLANT (ANFFP)
TO BE LOCATED NEAR PRATTVILLE, ALABAMA I
ADDITIONAL PROPOSED CONTENTIONS 0F INTERVENOR DAVID L. ALLRED Comes now David L. Allred and of fers os valid the follow-ing conteotions in connection with his petition to intervene in the above-captioned proceedings:
l I.
Title 10 C.F.R. 5 70.23(a)(7) crovides that before l
commencement of construction of a fuel fabrication facility the Director. of Nuclear Material Saf ety and Saf eguards must conclude that the issuance of a license is accropriate "after weighing the environmental, economic, technical, and other benefits agsinst environmental costs and considering available alternatives."
Moreover, such evaluation and conclusion must
[
be based on "information filed" and ths Environmental Impact l
I Statement.
Title 10 C.F.R. Part 51 requires Westinghouse to file an Environmental Report discussing alternatives to the l
i proposed action.
The Environmental Report filed by Westinghouse I
contains a section titled " Alternatives to The Proposed Action"
[
l purporting to deal with "the applicant's choice of a particular l
plant design and site selection."
That section also claims that y
the site selection is supported "through discussions of alter-natives considered."
t i
l 8010080 2 T t>
~
e 1
Page Two A.
Westinghouse has failed.to provide sufficient informa-tion for the Director of Nuclear material Safety and Safeguards
'to adequately weigh the environmental, economic, technical, and mther benefits against environmental costs, in thats 1.
The Environmental Report states that by "1985, 80 additional nuclear plants are er.pected to i ncrease...the nation's electrical supply."
However, the Westinghouse has relied upon projections based on information obtained from an April, 1979, report of the Department of Energy.
Such projec-tions occurred prior to the incident at Three mile Island and the subsequent re-evaluation of the propriety of continued nuclear energy production in this country.
Indeed, the year-long moratorium on licensing of nuclear plants has not been considered by Westinghouse nor has the increased concern on the part of the general public for nuclear saf ety been cnnsid-ered by Westinghouse.
The projected "80 additional nuclear plants" by 1985 is inaccurate and not a valid basis for considering additiona l f uel f abrication.
2.
With the advent of the nublic's and government's renewed concern for nuclear safety, additional tests and re-tests of existing nuclear facilities have been mandated.
New standards and stricter safety compliance raquirements in the construction j
w and operation of nuclear reactors makes the projection that b'y "the year 1990, a total of 189 nuclear plants" being in service unrealistic.
There will not be 189 nuclear plants in service by 1990 and the requirement uf fuel based on such prcjection is inaccurately overstated.
w
I
)
Page Three 3.
The Environmental Report states that "the current (1979) industry fuel fabrication capacity will be exceeded by 350 MTU's (or 11 percent) by 1983.
In 1984, demand for fuel.
fabrication capacity is exceeded by 32 percent, and this i
increases linearly throughout the 1980's and 1990's."
Westing-7 house admitted at the pre-hearing conference that the above statement and justification for the proposed facility is based on the worldwide nuclear inoustry.
Environmental costs, however, will be primarily restricted to the United States and prattville, A labama, in particular.
Westinghouse has failed to disclose the extent to which the proposed facility is designed to serve Westinghouse and other interests outside the United States.
Westinghouse cannot use " environmental, economic, technical and other benefits" accruing on account of extra-United States activitieu to offset environmental costs within the United States, yet such is precisely what Westinghouse seeks to do.
4 Not only has Westinghouse imoroperly considered benefits accruing outside the United States in balancing environmental ccsts within the United States, Westinghouse has over-stated such extra-territorial benefits.
The recent narrow Senate approval to ship nuclear fuel to India with the proviso that such shipments may be curtailed in the 'uture shows the i
tenuousness of the Westinghouse projection.
B.
Westinghouse has also failed to provide sufficient inf orma tion concerning "available a lternatives."
1.
Westinghouse summarily states in Section 7-1 2 of its Environmental Report that " Westinghouse has decided it would j
j i
Page four be most prudent to install its additional nuclear fuel fabrica-ting capacity at some location other than the Columbia facility.
The risk of loss to the ccantry's energy resources due to an
< unscheduled shutdown would be minimized in this case, since the nation's utilities would be assured of a second source of fuel fror. Westinghcuse."
a.
Westinghouse has failed to show that the environ-mental and other costs of building the proposed facility outweigh the costs of expanding its present facility.
There is no information concerning the costs of expanding the South Carolina facility either in terms uf environment or money.
b.
Westinghouse has failed to show the size of tne risk of an unscheduled shutdown of the South Carolina f acility which risk is infinitesimal.
c.
Westinghouse has failed to show that a second source of fuel from Westinghouse would be necessary for the United S tates nuclear industry.
Other suppliers could provide sufficient fuel in an emergency.
In short, Westinghouse has merely named the alternative of exoanding its South Carolina f acility without providing any data whatsoever to show that such an alternative is less desirable than building the proposed facility.
2.
Westinghouse has not identified any proposed site alternative for a new facility in spite of the NRC's request to do so.
See Lettor of Dr. E. Y. Shum dated June 3,
- 1980, transmitting questions to lestinghouse, including question
- 24, and Westinghouse's response dated July 8, 1980.
Neither
Page Five has Westinghouse giver " comparable data" for the allaged "20 sites in 16 states."
Environmental Report, p.
7-3.
Other sites are ecologically, economically and technologically more desirable and less costly than the proposed site..
3.
An examination of the map " Location of Nuclear power Plants in the United States," Environmental Report, p.
7-4, shows that a f acility in Kentucky, Ohio or West Virginia wculd be recre centrally located to serve existing and proposed nuclear power plants.
Such a location would also meet each of the criteria established by Westinghouse in its Environmental Report.
C.
Neither in its Environmental Report ner in any other material has Westinghouse examined the alternative of not increasing its fuel fabrication facilities on account of alter-native energy sources.
The United States is embarking on a large synthetic fuels program and is funding research in the areas of thermal, wind, and solar energy.
Westinghouse has completely ignored the implications and possibilities of such programs.
Current and probable near-future technologies in these areas are much safer and less costly in every respect than nuclear energy.
Alternative energy sources which are only now being given government support will make the risks of nuclear energy unacceptable before the need for or production of nuclear fuel at the proposed facility.
II.
Title 10, C.F.R. Part 51 requires that Westinghouse prepare an Environmental Report f or the proposed f acility, j
l The map and other materials provided by Westinghouse show that 1
the Prattville Experiment Station is located directly across County Road 4 from tha proposed site. (See Westinghouse response
Page Six to NRC Staff questions).
Approximat*ely SO acres of the Experiment Station are cultivated and various crops are grown.
Agricul-ture is one of Alabama's largest industries and much of the technology available to Alebama farmers is developed through Auburn University experiment stations such as the one located in Prattville.
Westinghouse bas, failed to evaluate the effect of its operations on the Prattville Experiment Station.
Environmental ef fects of the proposed f acility will adversely effect the reliability and utility of the Prattville Experin9nt Station and the experiments conducted at that facility.
III.
Westinghouse, in Section 13 of its license applica-tion seeks exemption from certain regulations promulgated by the NRC.
Westinghouse states the section of the Code of federal Regulations from which it seeks exemption, however, Westinghouse fails, in each instance, to state the reasons for seeking such exemption and the requiaite " good cause" upon which the exemption would be based.
Westinghouse has f ailed to show that the exemptions should be granted.
The exemptions sought by Westinghouse should not be granted for environmental, safety and health reasons as set forth belows i
A.
In Section 13-1 Westinghouse seeks exemption from the j
i requirement to " notify, in writing the director of the appro-i priate NRC Inspection and Enforcement regional office...at least 30 days before the date that respiratory protective equip-l ment is first used" because use of respiratory protective equipment is specifically addressed in the license application.,
However, Section S-3.4.3 of the license application deals with h
i
i l
l l
Page Seven t
respiratory protection only in a summary manner.
1.
Westinghouse has failed to identify.the times, procedures, locations, persons, or other identifiable criteria that constitute the situations "when it is impractical to apply process or other engineering cantrols to assure that concentrr-tions of radioactive materials in air are below limits specified in the license.
2.
part S-3.4.3 also states that "before initiating use of respiratory protective equipment...a written respira-tory protection program shall be prepared...."
Nowhere, however, l
has Westinghouse set forth such a program.
To grant an exemption j
before the respiratory program is prepared and evaluated t
by the NRC is improper.
3.
Westinghouse has also failed to provide a " description of equipment and facilities which will be used" in its respira-tory protection program as required by 10 C.F.R. 70.22(a)(7) j and 10 C.F.R. 70.22(8).
i Westinghouse has failed to show good cause for this l
requested exemption.
Westinghouse has also failed to provide I
an adequate basis for evaluating its request for the exemption.
Westinghouse, by its failure to provide the above information l
l and data, has not submitted "a complete and accurate disclosure i
as to all matters and things required to be disclosed." 10 C.F.R. 5 70.22(e).
i B.
In Section 13-2 Westinghouse seeks exemption from 10 C.F.R. 20.203, " Caution Signs, Labels, Signals, and Controls" by posting a general tearning as set forth in Section 13-2 of the i
page Eight license application.
Such a general warning is no warning at all.
The very reason for requiring specific warning and caution labels is to alert people to dangerous conditions.
Following the rationale of Westinghouse's proposed alternative warning, i.e.,
"Every container or vessel in this area may contain radioactive material (Emphasis added)," a similar sign at the entrance to the facility would be adequate.
Westinqhouse has failed to state good cause for the requ3sted exemption.
Westinghouse has also failed to show that its"preposed procedure to protect health and to minimize danger to life" 1U C.F.R. 70.23(a)(4) is adequate.
The alternative proposed by Westinghouse is inadequate and creates an unreason-able health hazard to facility employees.
C.
In Section 13 3 Westinghouse seeks exemption from the
" General Recuirement" for disposal of licensed material in favor of being permitted to " abandon or dispose of small quanti-ties of source, special nuclear, and byproduct materials which are present" on items retained for record purposes.
1.
Although Westinghouse sets forth recommended
" contamination limits" for two nuclides, no such limits are proposed for other contaminants which will exist in the facility.
Such failure fails to meet the requirements of 10 C.F.R. 70.23(a)(6) requiring a summary description of fundamental material controls, with respect to such other nuclides and contaminants.
2.
The above-stated failure to consider other contam-inants which may possibly be contained on records also violates 10 C.F.R. 70.22(e) requiring that the license application contain I
Page Nine
" complete and accurate disclosure as-to all things required to be disclosed."
3.
Westinghouse has also failed to assess the cumu-lative effects of its requested exemption.
Over the projected life of the plant such cumulative effect of " abandonment" and improper dispositien of special nuclent materials will create a health hazard to facility employees and the environment.
4.-
Co-mingling of contaminated material with non-contaminated material, as proposed by Westinghouse will make future recovery of dangerous radioactive materials extremely difficult if not impossible.
5.
Westinghouse has f ailed to establish that the data contained in contaminated materials would be transferred and retained in or on a non-contaminated source.
Therefore, Westinghouse has failed to show that it can or will meet the requirements of record keeping established by the NRC.
Westinghouse has failed to show good cause for its requested exemption and has also failed to provida adeauate information to evaluate its request for exemption from 10 C.F.R. 20.301.
D.
In Sectici 13-4 Westinghouse senks permission to maintain records in units other than those required by 10 C.P.R. 20.
Such exemption constitutes an unreasonable risk to the health and safety of facility employees and the public and also consitutes an unnecessary impediment to the monitoring of such records by the NRC and the public in that the use of other units will be misleading to the NRC and to the public and will result in miscalculations and errors; Moreover, Westinghouse has shown w
.m,
n-
Page Ten no reason or good.cause for its request.
E.
In Section 13-5.1 Westinghouse requests that " licensed activity shall be exempted from the monitor alarm requirements of 10 C.F.R. 70.24" in certain specified locations under certain specified conditions.
Westinghouse has failed to show good cause for the requested exemption.
Westinghouse has also failed to define certain language used in the requested exemption such as " administratively limited," " remote from other operations with special nuclear materials (emphasis added)" "nuclearly isolated" and " area."
1.
The requested exemption is not sufficiently specific to evaluate the propriety of granting the exemption.
2.
The requested exemption constitutes an unreasonable hazard to the environment and to the health and safety of facility employees and the public.
F.
In Section 13-5.2 Westinghouse requests exemption f rom criticality accident requirements, 10 C.F.R. 70.24 at 2ne loading location under certain conditions.
Westinghouse has failed to show good cause for the requested exemption.
The requested exemption consitutes an unreasonable risk to the environment and to the health and safety of facility employees and the general public in that:
1.
There will be no monitoring system meeting the recuirements of 10 C.F.R. 70.24 in an area where licensed special nuclear material is handled.
2.
No emergency procedures will be maintained in the l
exempt areas to assure the safety of personnel in the area.
I i
s
7 page Eleven 3.
No means for quickly identifying individuals who have received doses of 10 rads or more will be maintained.
4 The reauirements of 10 C.F.R. 70.24(b)(2) will not be followed in areas prone to criticality.
G.
In Section 13-6 Westinghouse seeks exemption from the requirements of 10 C.F.R. 70.42, Transfer of Special nuclear material with respect to the " transfer of hydrofluroric acid containing trace quantities of uranium...to nonlicensed persons" under specified conditions.
Westinghouse has failed to show good cause for the requested exemption.
Westinghouse seekt, by such exemption, to shift.its re spon c ibli t y for controlling special nuclear material to persons who are unlicensed to handle such material.
The reques'ted exemption consitutes an unreasonable risk to the environment and to the safety and health.of the general public in that i
1.
Westinghouse's propuued " written instruction" l
and conditions to the first transfereo does not adequately protect or inform subsequent recipients of the hydroflurorie acid.
2.
Westinghouse's proposed conditions are inadequate to prevent human consudiption of the hydroflurotic acid.
IV.
kestinghouse, by requesting the above exemptions, I
has failed to adequately addrest the license requirements of 10 C.F.R. 20 and 70 with respect to those activities for which exemption is requested.
Therefore, Westinghouse has failed to submit a license application which contains " complete and i
accurete disclosure as to all matters and thingr required to be
Page Twelve disclosed." 10 C.F.R. 70.22(e).
A license application cannot be evaluated or acted upon until such disclosure is made.
V.
In its license application Westingho*ise states in its specifications introduction that "These specifications shall be the inspectable portion of the described facility license."
License Application,
- p. 5-1.
Section 7 of the License Applica-tion states that the comprehensive Nuclear Materials Control and Accounting plan "shall be kept part of the Demonstration Section."
Section 18 of the License Application states that the Plan is submitted as a secarate document.
Sections 8, 9-4, 10-3, 11, and 12-2 also refer to documents which are to be kept part of the Demonstration Section.
Sections 19, 20, and 21 of the Demonstration Section, in turn, refer to sep7. rate documents.
Westinghouse has failed to provide a k
complete license application and to meet the recuirements of 10 C.F.R. 70.22( a) in that t A.
The above-referenced sections of the license i
application have not been completed or provined.
l 9.
Westinghouse has f ailed to show good cause for not l
submitting a complete license application.
C.
Westinghouse has failed to show any reason or good cause for failing to submit or disclose the information requited in the above sections either separately or severally.
David L. Allrsd specifically reserves the right to file j
additional contentions based on any additions or supplements to t
the license application whether as set forth above or not, includina but not limited to information per taining to nuclear f
t page Thirteen materials control and accounting, physical security, shipping containers, delivery of special nuclear material to a carrier for transport, emergency control, and decommissioning of facilities and grounds.
VI.
In Section 15-1, General Licensed Activity Infctmation; 15-2, Detailed Operations Evaluation; and 15-3, Organization i
and Administration, Westinghouse states that information will be supplied.
Westinghouse, by not supplying the required Saf ety Analysis has f ailed to meet the requirements of 10 C.F.R. 7D.22(e).
David L. Allred specifically r eservos the right to file additional contentions based on any material or information supplied by Westinghouse pertaining to the required Safety Analyisis and Section 15 of the license applicstion.
VII.
In Section 16 of its license application Westing-house states that a Regulatory Compliance manual reovired by 10 C.F.R. 70.22(a)(8) is or will be'sumbitted as a separate document.
Such document is unavailable to David L. Allred and he specifically reserves his right to make further conten-tions based on information contained in such manual.
The license application is incomplete without such information anc cannot be acted upon by the NRC until such information is supplied.
VIII.
In Section 17 of its license application Westing-house states that an ALARA manual is or will be submitted as a separate document.
Such document is unavailable to David L. Allred and he'specifically reservec the right to make
]
4 r
n
page fourteen further contentions based on information contained in such
]
manual.
The.llcense application is incomplete without such material and cannot be' acted upon by the NRC until such information is supplied.
IX.
As set'forth above in contentions V through VIII the license application is incomplete and does not meet the requirements of 10 C.F.R. 70.22(e).
X.
The license application does not meet 10 C.T.R.
requirements pertaining to possession of special nuclect materials.
A.
The application does not meet the requiremento of 10 C.F.R. 70.22(a)(4) in that it ooes not contain:
1.
Chemical and physical forms of enriched uranium and U-233 to be used at the ANFf P; 2.
Isotopic content of special nucioar materials, specifically failing to orovide isotopic content of uranium at enrichment above 5 percent of U-235.
8.
The application does not meet the requirements of 10 C.F.R. 70.23 for approval by the Commission.
1.
The commission cannot determine that the applicant's proposed equipment and facilities are adeauate, per requirements of 10 C.T.R. 70.23(a)(7) due to failure of applicant to provide form and isotopic content of special nuclear material to be processed; 2.
Adequate procedures to protect health and to minimize danger to life or property cannot be ascertained by the Commission due to the omission of information pertaining to form and isotopic content of materials to be processed under the license.
i page Fifteen l
XI.
The license application does not meet 10 C.F.R.
licensing requirements pertaining to use of special nuclear materials.
A.
The license application does not meet 10 C.F.R.
requirements pertaining to contents of application in that:
1.
It does not meet requirements of 10 C.F.R. 70.22(a)(2) in that it does not contain all activity for use of special nuclear material nor general plan for carrying out unspecified activities.
Application specifically omits:
a.
The activity and plan for conversion of unspecified uranium compounds into other unspecified uranium comoounds; b.
The plans pertaining to recosery of off-site radioactive scrap and waste; c.
The activity and clan for use of highly enriched U-235 and U-233, 2.
The license application does not meet the requirements of 10 C.F.R. 70.22(a)(6) in that it fails to describe the training and experience of applicant to engage in proposed activities, in thats a.
All proposed activities are not specified; f
b.
.Specified activity of converting uranium hexa-t flouride to uranium hexafluoride to uranium oxido powder by
" dry" process is experimental process in which applicant has t
no training or experience.
3.
The license application does not meet the recuire-ments of 10 C.F.R. 70.22(a)(7) in that it failes to describe the equipment and f acilities to protect he alth and minimize life t
Page Sixteen 1
and minimize danger to property in carrying out unspecified activities.
The application' omits:
J Equipmant and facilities for unspecified activity of a.
converting uranium ^ compounds into other unspecified uranium Compounds; b.
Handling device, shields, disposal devices, etc.,
for U-233.
Minute quantities of U-233 can cause serious biological damage and its use recuires special f acilities.
4 The license application does not meet the require-ments of 10 C.F.R. 70.22(a)(8) in that procedures to protect health and minimize danger to life and property are not included for the unspecified activities.
5.
The license application does not meet the require-ments of 10 C.F.R. 70.23(3) in tha t it does not contain complete and accurate disclosure as to all matters and things required to be disclosed.
B.
The application does not meet 10 C.F.R. requirements for commission approval of application, specifically:
1.
The application does not mee t the requirements of 10 C.F.R. 70.23(a)(2) in that the commission cannot determine that applicant is cualified by reason of training and experience to use ma terial for the purpose reauested because:
l W'stinghouse does not provide specific use for a.
e special nuclear materials; i
b.
Westinghouse does not have training and experience in material use in " dry" conversion process.
C.
Issuance of license for unspecified activities would l
be a threat to the national defense, in violation of 10 C.F.R. 70.23(d) in that Westinghouse would be licensed to supply potential
i i
page Seventcen I
weapons-grade uranium compounds internationally.
XII.
The license application does not meet 10 C.F.R.
requirements pertaining to training and experience of applicant.
A.
The' license application does not meet the requirements of 10 C.F.R. 70.22(a)(6) in that it does not state the technical qualifications, training and experience of the applicant.
-Further and specifically, the application does not contain the technical qualifications, training and experience of 1.
Line management components responsible for all operations and activities involving licensed materials; 2.
Shift supervisors, though application states that shift supervisors shall'be first-level line managers.
3.
The license application does not contain adequate technical qualifications, training or experience oft a.
The regulatory compliance manager, while stating he shall be responsible for assuring evaluation of nuclear criticality safety and radiatien recuirements; b.
The criticality engineer nor of individuals who will compute or perform other criticality services; c.
The health physics engineer, though application states that he shall establish and evaluate ALARA radiation
{
l protection program.
The application also demonstrates that the engineer, the only staff member acquainted with radiation l
protection,wllis i
(1) have no authority; (2) not serve as a member of the Regulatory Compliance Review Committee.
a
Page Eighteen i
d.
Designees, though application states designess may carry out the duties of the criticality and health physics engineers.
XIII.
The license application does not meet federal requirements pertaining to equipment and facilities which will be used to protect health and minimize danger to lif e and property.
A.
The application does not meet the requirements of 10 C.F.R. 70.22(a)(7) in that it does not contain a description of equipment and facilities, such as:
1.
Handling devices; 2.
Working areas; j
3.
Shields; 4
Measuring and monitoring instruments; 5.
Devices for the disposal of radioactive affluents l
and wastes; 6.
Storage facilities; 7.
Criticality accident alarms, etc.
B.
The application does not meet the requirements of 10 C.F.R. 70.23( a)( 3).
1.
Installation, modification or relocation of special
)
I nuclear material handling, processing or storage eouipment will not be adequate because:
a.
It will be approved only by the regulatory compli-ance component and this component lacks expertise in this area; b.
All special nuclear material handling, processing and storage equipment will not ce included in the review.
Page Nineteen 2.
Equipment tests _will'not be adequate.
a.-
According to the license application, tests will be limited to emergency evacuation signals and permanently I
mounted air sampling equipment.
b.
Once-a-year test of air sampling equipment is not adequate for the' protection of health.
3.
Engineered safety of the ANFFP Special Nuclear Materials Building will not be adequate to protect health or minimize danger to life and property.
a.
The application states SNM Building will not meet Southern Standard Building Code; b.
The application states only that SNM Building shall be designed, constructed and operated for insurability; c.
Building will not be designed and constructed to:
(1)
Withstand nuclear criticality; (2)
Prevent contamination to the environs through containment.
d.
The walls will be used for shielding, based on Westinghouse's assumption of normal incidence, while most accidents are not normal incidents.
4 Storage racks and neutron isolation structures imoortant to nuclear criticality safety are not adequate and will be designed only for credible loads, without unforeseen mishaps taken into consideration.
S.
HVAC systems will not be adequate, since:
a.
The application states HV AC systems will be permitted design variance, without specifying nature of proposed variances; b.
EEPA filters are rated 99.9 percent efficient, but l
this is applicable only at installation;
Pege Twenty c.
Passing effluent through HEPA filter units does not guarantee the protection of the public and the environs from the' release of significant amounts of radtoactivity; d.
Confinement will not be adequate since:
(1)
Effluents may pass through only one HEPA filtration before release to the environment:
(2)
Containment can be achieved only when provision is made to retain collected radioactive material.
e.
The application states ventilation pickups may be used for airborne radioactivity control.
This will affect public safety and health since:
(1)
Highly radioactive air could cass through only one HEPA filter (which could be clogged) before release into the environment; (2)
A local ventilation shutdown should be used to isolate radioactivity in the building, rather than distri-buting it to the environment.
f.
Provision for continuous representative air sampling of gaseous effluents discharged from recirculating air systems of stacks and vents is not adequate, for:
(1) westinghouse has not shown that stack and other releases will not be returned to the building; (2)
Recirculating air systema do not include filter units capable of effectively reducing concentrations of radioactive materials in effluent;
( 3)
Air sampling is not adequate as Westinghouse does not show how it will be representative of concentrations inhaled by exposed personnel;
Page 21 (4)
Periods of analyeis of air sempling are not indicated, ttiereby rendering air sampling equipment inadeavstc.
f:.
Confinement system is inadeauste, in thats a.
The application states only that system will consider use of fire-resistant materials, minimization of accumulation of special nuclear material and ease of decontamination.
Such statements are ambiguous and do not provide adequate assurance.
b.
The application does not discuss placement of ventilation heads; c.
Hoods for chemical effluents are exempted in application, while the hazards of chemical toxicity are as great as fire and criticality hazards; d.
The license application states that all confine-ment precautions may be permitted design variances.
Without further specificatioW as to the nature of such variances, true saf ety cannot be evalua ted.
7.
Radiological waste handling system souipment and facilities are not described in the license apolication and the application also states that the unspecified systems are subject to variance.
8.
Toxic waste handling is not described in the license application, which omits equipment and facilities for handling toxic wastes.
9.
Gaseous radiological waste handling will not be adequate to protect health and minimize danger to life and property because:
-0
~ '
Page 12 a.
HEPA filters will not prevent significant releases j
to the environment; c.
Westinghouse will not be able to ascertain quality of the released gaseous radiological wastes en air sampiling equipment will be tested only annually.
- 10. The proc'ess and service waste souipment and facilities will not be adequate.
a.
The application states only that provision may be made for degrading uranium as special nuclear material to source material as part of waste treatment; b.
The application states that provision shall be made for measuring volumes of treated process and service wastes released from plant, buts (1)
Page S-50 of the license application demonstrates that columes of effluents released at each liquid sampling station are not applicable; (2)
The "orovisions" ara not specifically set forth.
11.
Solid radiological waste handling is not adequate.
a.
The application does not specify equipment for handling or determining radioactive levels of waste; b.
The application states radioactive solid waste may be sent to a nonlicensed disposal facility, 12.
Emergency power equipment is not adequate in that i
l it does not provide for safe and automatic shu+,down of process equipment.
Page 23 13.
Fire protection is not adequate to protect health and minimize danger to life and property.
a.
The license application states that low combus-tibility HEPA' filters will be considered, with no assurance of their use.
b.
finely divided uranium is pyrophoric in nature.
Large, concentrations of such small particles in the HEPA filters will constitute a fire hazard.
c.
The SNM Building design shall only consider construction which will confine fire and subsequent contamina-tion as closely as practible.
The criteria for considerations are not set forth, d,
There will be no automatic fire sprinkler system in areas of SNM Building where highly pyrophoric uranium dust c
will accumulate.
e.
There will be no other automatic fire suppression system in areas of SNM Building where highly pyphoric uranium is stored, processed or handled.
f.
The license application states portable fire extinguishers shall be provided for fire protection.
(1)
Such equipment is inadequate to control or extinguish fire.
(2)
Such method of fire suppression will greatly endanger the lives of individual firefighters; (3)
Type and number of fire extinguishers is not provided;
f i
Page 24 g.
Merely posting of permissible fire-fighting equipment and materials is not adequate without training and drills.
14 Instruments and operations recuiring interlocks for safety of workers and environs are not identified in the license ~ application.
i 1
15.
Alarms are not adequate to protect health and minimize danger to. life and property.
a.
The license application states no prov:sion for separate alarms for fire, criticality o_r accider*?! release of radioactivity from confinement.
A common alarm for all emergency situations will not alert oersonnel about soecific hazard.
b.
The license application states that immediate evacuation alarm will be audible og visible.
This is inadequate as an alarm which is not audible and visicle to all personnel at all times is not an adequate alarm.
16.
Process and service alarms will be inadequate to safeguard facilities, workers and environs.
a.
The license application states alarm will not be audible to cognizant personnel responsible for corrective actior, b.
There is no provision for testing of process and service alarms other than following installation and major repairs.
17.
Equipment design will not be adequate to preclude critical configurations.
a.
Failure modes may be based on operation experience, b.
Westinghouse does not have operational experience in " dry" fuel fabrication.
l page'25 l
c.
The probability of criticelity is not subject to l
reliable quantitative prediction.
d.
Double-batching, which is not uncomnion in nuclear f uel f abrication, occurs due to human error.
e.
Fire hazards are not considered.
f.
Criticality saf ety signs are not adequate protection, g.
Low density construction materials such as wood and plastic may be disregarded in determining spacing, according to license application.
18.
Air sampling equipment will not be adequate to protect healtt and to minimize danger to life or property.
The application states that air monitors will be used in lieu of fixed-position air samplers.
a.
Westinghouse does not state maintenance requirements or sensitivity of air-sampling equipment, b.
Westinghouse does not state location of air-sampling points.
c.
Equipment will not represent the concentrations inhaled by exposed personnel (1)
Air-sampling equipment will no t (uplicate inhalding and exhaling rate of an average individual.
(2)
The system will not indicate nor segregate materials that will be retained in upper and lower respiratory systems of individuals exposed to high concentrations of radioactivity.
19.
The type of dosimetry souipment to be used is not described in the license application.
l 1
. l
i Page 26 20.
Protective clothing proposed for use by Westing-1 house is not adequate.
The license application does not provide 1
. fort a.
Headcovers; b.
Cloves; c.
Plastic overcovers.
21.
Respiratory protection equipment is not adequate.
The license application does not contains a.
The type of respiratory protection equipment proposed for use; b.
Assurance that respirators will be available to all personnel subjected to high levels of airborne radioactivity.
c.
Monitoring, inspection, decontamination, repair and sterilization equipment for respiratory protection equip-ment.
22.
Nuclear criticality detection equipment is not adequate.
The application states a.
Intention of Westinghouse to continue work during nuclear criticality detection outage; b.
That portable instruments may be substituted, not shall be used.
This does not assure nuclear criticality detection.
Respectfully submitted, v
' David L. Allred 231 Dak Forest Drive Montgomery, AL 36109
CERTIFICATE OF SE:, ::E I hereby certify that I have ser;ec a copy of.ths foregoing upon the following named parties by ailin; the sace to them on this the
/
_ day of 4/L 1980 John F. Wolf, E sq., Chairman Dr. v artin J. Steindler, Member Atomic Safety & Licensing Od.
A :-ic Safety & Licensing Bd.
3409 Shepherd Street Ar;:nne National Laboratory Chevy Chase, MD 20015 97C; South Cass Avenue Ar;:nne, IL'60439 Dr. Harry f oreman, member Atomic Safe ty and Licensing 8d.
9ar ton Z. Cowan, Esq.
Box 395, Mayo E c '< e r t, Seamans, Cherin & Mellot Univ. of. Minnesota 42 : Flocr Minneapolis, MN 55455 6C: :: ant Street Pi:.scurgh, PA 15219 Donald R. Marcucci, Esq.
. Law Dept.
Oc:< sting & Service Section Westinghouse Electric Corp.
Of' ice of the Secretary P. D. Box 355 U. 5. Nuclear Regulatory Comm.
Pittsburgh, PA 15230 Tas.ington, DC 20555 Julian L. Mcphillips, Jr., Esq.
Sheriin Turk, Eso.
P. O. Box 64 Le;al Staff 516 South Perry Street U.
- 5. Nu;; ear Regulatory Comm.
Montgomery, AL 36101 wa s 91 ng te n, D.C. 20555 Dr. I ra L. Myars, M.D.
At:-ic Safety & Licansing 9d. Panel State Health Officer U. 5. Nuclear Regulatory Comm.
i State of Alabame Was-ingten, DC 20555 Dept. of Public health State Office Building At:-i: Safety & Licensing Appeci pan 91 Montgomery, AL 35104 U. 3. Nuclear Regulatory Comm.
ar-ia;t:n, DC 20555 n, 7.
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