ML20217F023

Petition to Intervene.* Petitioners Request to Be Permitted to Intervene in Listed Proceedings

ML20217F023
Person / Time
Site:	Millstone
Issue date:	10/06/1999
From:	Burton N AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20217E989	List: ML20217E984 ML20217F003 ML20217F023 ML20217F043
References
LA-3, NUDOCS 9910200173
Download: ML20217F023 (4)

Text

t DOC 2 EU UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAllo OT -7 P 4 :08 In-the Matter of

Docket No. 50G423 A^f NORTHEAST NUCLEAR ENERGY COMPANY (Millstone Nuclear Power Station, Unit No. 3)

October 6, 1999 PETITION TO INTERVENE The Connecticut Coalition Against Millstone ("CCAM) and the Long Island Coalition Against Millstone (" CAM") herewith respectfully petition to intervene in the application proceedings whereby Northeast Nuclear Energy Company ("NNECO") requests issuance of an amendment to Facility Operating License No. NPF-49 to permit high-density spent fuel storage racks at Millstone Unit 3. This petition is submitted in accordance with the provisions of 10 CFR S2.714.

In support of their intervention, the Petitioners represent as follows:

1. The Connecticut Coalition Against Millstone is an

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organization of individuals and groups located in the State of Connecticut concerned about the safe operations of the Millstone Nuclear Power Generating Station. CCAM is based at 13 Water Street in Mystic, Connecticut.

2. CCAM's membership includes individuals and families, including fami'ies with young children, who own property and reside in the immediate vicinity of the Millstone Nuclear Power Generating Station in Waterford, Connecticut.

3. Long Island CAM is an organization of individuals and 9910200173 991014 PDR ADOCK 05000423 C

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l groups located on Long Island in the State of New York concerned about the safe operations of the Millstone Nuclear Power Generating I

Station. It is based at 66 Newtown Lane,. East Hampton, New York.

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4. CAM's membership includes individuals and families, including l

families with small children, who own property and reside within the emergency evacuation zone of the Millstone Nuclear Power Generating Station.

5. NNECO proposes in the subject amendment to increase the number of highly radioactive spent fuel assemblies that can be l

stored in the Millstone Unit 3 spent fuel pool from the 756

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assemblies for which it is presently licensed to 1,860, thereby more than doubling the spent fuel capacity with an increase of 1,104 l'

assemblies..

6. NNECO asserts an increase in spent fuel storage capacity l

l is needed to maintain the capability for a full-core off-load.

7. Millstone Unit 3 presently lacks full-core off-load capacity.

8. Millstone Unit 3 has lacked full-core off-load capacity since performing the most recent refueling outage which began on May 1, 1999.

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9. If penaitted, the. license amendment would allow a temperature increase concomitant with a displacement of cooling water in the spent fuel pool.

10. If permitted, the license amendment may contribute to greater exposure of plant personnel to radiation.

11. If permitted, the proposed activity will increase risk 2

s to the. general'public.

12. Such risks are foreseeable and potentially catastrophic.

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More particularly, the Petitioners represent that the subject licensing. amendment is' deficient and potentially unsafe as follows:

(a) NNECO.has not conducted a sound and prudent evaluation

.of the alternatives to the proposed use of high density storage r

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racks; l

(b) The safety analysis prepared for the license amendment application is non-conservative and it does not bound the risk from the proposed activity because it only examines the consequences from the partially blocked flow channel when there l

are credible scenarios in.which the entire flow channel, or even multiple flow channels, can become fully blocked; (c) The safety analysis prepared for the licensing auendment 1

application is non-conservative and it does not bound the risk l

-from the proposed activity because the evaluation of dropping an empty high density rack into the spent fuel storage pool during l

installation failed to consider the potential for a dropped rack

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f impacting a storage rack containing irradiated fuel; (d) The. activity proposed in the. application represents an undue and. unnecessary increase in risk because it increases the dependence on administrative controls to prevent undesirable consequences; (e) The proposed activity significantly increases the probability of a criticality accident in the spent fuel pool 3

r l-because it removes an existing barrier; l

(f) The proposed' activity increases the probability of an i

accident because it significantly increases the capacity of the

. irradiated fuel assemblies stored in the spent fuel pool -- and l

thus the associated decay heat load -- while reducing the amount of water in the pool.

14..The Petitioners incorporate by reference herein the " Declaration of David A. Lochbaum, Nuclear Safety Engineer, Union of Concerned Scientists, Concerning Technical Issues and Safety Matters Involved in the Millstone Nuclear Power Station I

Unit 3 License Amendment for Spent Fuel Storage" dated October 4, 1999, the original of which is annexed hereto.

15. The Petitioners object to issuance of the requested i

licensing amendment.

16. Were such licensing amendment to be issued, the Petitioners would be subject to great risk of injury to life, limb and property, which risk they are unwilling to assume.

i WHEREFORE, the Petitioners request that they be permitted to j

intervene in these proceedings.

i CONNECTICUT COALITION AGAINST MILLSTONE l

[Long Island] COALITION AGAINST MILLSTONE By:

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Nancy,B('rton, Esq.

147 fross Highway Redging Ridge CT 06876 Tel. 203-938-3952 Fax 203-938-3168 Fed. Bar. No. 10836-ct j

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