ML20206M062

Comment Opposing NUREG-1437, Generic Environmental Statement for License Renewal of Npps, Supplement 1, Calvert Cliffs NPP

ML20206M062
Person / Time
Site:	Calvert Cliffs
Issue date:	05/04/1999
From:	Mills R MARYLAND SAFE ENERGY COALITION
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-64FR11071, RTR-NUREG-1437 64FR11071-00010, 64FR11071-10, NUDOCS 9905140184
Download: ML20206M062 (5)

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~U.S.: Nuclear Regulatory Commission Washington, D.C. 20555-0001 From: Robin Millh Director, Maryland Safe Energy Coalition 1443-;Gorsuch Avenue I Baltimore, Maryland 21218 Phone # (410) 662-8483- Fax #'(410) 235-5325 E-mails raills4@bcpl. net POBox #33111, Bakt.21218 Re:. Written comments on NUREG-1437, " Generic Environmental l

Impact Statement f or License Renewal of Nuclear Phants,"

Supplement 1, Calvert' Cliffs Nuchear Power Plant LDate:'May 4th, 1999

Dear.reguuators,

My contention is that license renewal should be denied.

-Point 1.

Baltimore Gas and Electric Company, now known as Constellation Energy Group (CEG), has failed to justify need forithe proposed act6on. Page-xiii, Line 33 of the GEIS states ". . .t o meet f eture generating needs , as such needs may be determined by state, utility, and,-where authorized, Federal (other than NRC) decisionmakers."

. CEG has totally failed to justify need f or this action.

je .The current, license is good f or fif teen more years. The

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need for electric generating capacity at that time is unknown .and depends - on f actors such as conservation of energy, new sources-and what will happen as a resuht of I

O utility deregubation. I ask.that license renewal be denied -

until the year 2009, when'need for the proposed action can tur better assessed.

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1 IPoint 2.

Page.5-3, line 38 of the GEIS puts-the Cor.e Damage Frequency at. 3.3x10-4 per reactor year. Since.the company has two reactors,land license extension is f or 20.3 ears:

.00033 x 2 reactors x 20 years = one chance in 75 a core damaged s when the CCNPP was initially licensed the people agreed to aicertain risk for.a defined amount of time. I argue that license extension breaks this written promise made 25 years ago by increasing the. risk to the public, shareholders and compar.y beyond that orginally agreed to. The damage to GPU af ter the Three Mile Island core meltdown is used as reference. One chance in 75 that such an accident might occur

.is simply unacceptable to all stakeholders. I ask that license renewal be denied as 'long as it . represents this unacceptably high level of risk.

Point 3.

Page 8-25, tane 25 thru 27 states that energy management is not a possible replacement for CCNPP ehectricity. This is a lie, and I ask that this statement be struck from the

~EIS. It is a lie, because currently available energy conservation technology can replace CCNPP electricity ,

several f old over, and because technology advances over the next 15 years.are unknowable to make such a statement, and because utility deregulation means other electricky providers may replace CCNPP power with cheaper alternatives.

Conservation would also be much cheaper than license renewal.

At a minimum, license renewal should be delayed until 2009 so that. a projection of demand during the extended license period ' can have some credabils ty.

Point 4.

ThesUlcense renewal prcossa is illegitamate because the nuclear waste created over the license renewal period has been excluded from the precess. .This is a matter so important that the court syntes may have to resolve it.

I Excluding that nuclear waste from consideration in the EIS shows bias , industry favortism, is t.scalled f or , and e

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I will be the eventual downfall of the entire process. I demand consideration of the addition of 20 years of spent fuel creation and storage be incHuded. in the lucense renewal process. I specifically object uo page 2-24, lines 24 and 25 of the EIS. The accumulation of activation products in the materials of the containment building must increase over the life. cycle of reactor operations, therefore the statement that exposures will not' increase is a lie and must be removed from the EIS. Exposures will increase to workers entering tae containment building as surely as the sun rises every day.

Furthermore, the likelyhood that repairs will be needed inside the containment building will also rise as plant equipment ages.

This duel effect means much higher exposures f or the workf orce.

Point 5.

CEG seeks to operate CCNPP f or 60 years. No nuclear power plant anywhere in the worbd has operated for more thaa 35 years.

Because of the non-existant' historical record for extended operations, the license extension should be labeled as an experiment, with special provisions for extended license revocation should unexpected aging rebated problems arise.

The experimental nature of bicense extension warrants speciul caution, by our federal regulators in whom we trust.

Thus, what I ask, is that the operating license given for CCNPP not be identical to the original operating license, but that it be somewhat more restrictive, especially reguarding aging related and maintenance matters which might more seriosly effect an older nuclear plant.

Point 6.

Vertical tendons inside the containment building have been suffering unexpectedly high rates of brittle fracture failure. ~ In a letter to me dated 8 February 1999 on this subject I read about how CEG engineers are fixing this probbem inside the containment building. I quote from Nuchear Reactor Engineering, by Samuel Glasston.e and Abexander Sesonske, 1994, page 435, section 7.77, sentence 1, "As with metalm in general, exposure to radiation causes hardening and embritthement of stainless steel."

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4 This neutron induced embritt hement probbem is widely known and acknowledged, and as such shoubd be a matter of intense scutiny in the EIS. I contend that this probbem alone.should rule out any license extension as being to dangerous an increase in risk to the reactor and as a possibbe

-accident initia^or. Accidents do cause environmental impacts.

Point 7.

Again I quote from Nucbear. Reactor Engineering, page 434, section 7.70, second sentence, "However, there is a possibility that accident sequences leading to the injection of emergency coolant water woulo resubt. in combinations of vessel temperatures with thermal and pressure stresses that ,

i could lead to catastrophic vessel fracture." and on the same i page is the statement, "The feasibility of the lifetime extension may indeed depend upon the NDT temperature margin available."

The NDT (Non-ductihity Transition) temperature rises very slightly every year CCNPP operates. Considering the potential severity of an accident with catastrophic vessel failure, and

, the above quoted expert opinion on the subject, I request a special section with detailed analysis on this specific problem and the unique additional risk it entaius to extended operation be included in the final EIS before any hicense extension is granted.

Point 8.

The NRC's 10CFR50, app.H concerns the reactor vessel material surveElance program. At the public hearing in Solomons, Maryland, I maked about those samples, and was told that there are currently only two samples remaining. I request that data concerning the results of the tests done on the first three samples be included in the final EIS, and data from the generic trend curves in regubatory guide 1.99 reguarding NDT trends all be included in the final EIS so that the public has a better idea of the risk involved in extended operation to the unrepbaceabbe recctor pressure vessel. I withdraw this request if CEG phand to rephace the reactor pressure vessel.

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, 5 Point 9.

.In a document dated 19 March 1999, re a summary of the February 10, 1999 meeting between BG&E and NRC over the issue of CCNPP license extension, there is an unnumbered page within enclosure 2 t6tled System-Specific ARDI Issues that I find fault with. The quote is, "For all of these systems EXCEPP the RCS, the licensee uses ARDIs to confirm ef fectiveness of chemistry controus."

Using chemistry controls alone on the Reactor Control System is not acceptabbe. Not only is_this system subject to age related degradation problems (ARD), but it is in a high radiation field subjecting the system to ncutron embrittlement concerns, and the system is a primary safety i 1

system which-has no backup!!.! If the CRDM fail, how do you '

plan to shutdown? Should parts break inside causing jamming then chemistry controls will not discover the problem. A physical inspection should be required f or this system.

Due to the high level of radiation, remotely controlled cameras should be used to limit personnel exposures, and that procedure is probably good enough to certify that the RCS system is OK.

End. i 1

cc: NRC l Sen.' Paul Sarbanes l Sen. Barbara Mikuiski Paul Gunter, NIRS l

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