ML20003H521

Suppl to Oh Citizens for Responsible Energy 810311 Petition to Intervene,Enumerating Contentions to Be Litigated. Contentions Concern Clam Biofouling,Steam Generator Reliability,Radiation Blocking Agent & Steam Injury

ML20003H521
Person / Time
Site:	Perry
Issue date:	04/30/1981
From:	Alexander J OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	NRC COMMISSION (OCM)
References
ISSUANCES-OL, NUDOCS 8105060262
Download: ML20003H521 (7)

Text

.{,*

April 30, 1981 tiNTTED P.!'ATES OF AMERICA I:t' CLEAR E1ULATORY COMMISSION In tre Matter of )

)

THE CLEVELAND ElEC"'RTC I !,Lt!.' INATI: G )

C0'iPAtlY e t c.l. ) Docket flos. 30 440

) 50 44'.

(Perry fluclear Power i lt.nt, ) (Operating License)

Units 1 and 2) )

_ . )

00DE'S SUPPLEMEllT TO ITS PETITIO!! FOR LMAVE TO IrlTERVENE OCRE (Ohio Citizens for Responsible Energy) filed its Petition for Leave to Inte rvene with Secretary of the Commission on ihrch 11, 1981. 1ursuant to the Federal Rekister notice (February 13, 1981) anet the Atomic Safety and Licensing Board's Memo and Order of April 9, 1931, OCRE now files its Supplement to its Petition, said supplement enumerating those contentions which OCRE seeks to have litigated in this matter. The conten-tions are attached.

Respectfully submitted, Jefi Alexander OCRE Representative

~~~

attachment: Contentions -

cci Executive Le e;al Direc tor, NRC Gerald Charnoff, Esq. .% ,

Docketing an ! ?rvice Sec tion, Of fice of the Secretary, NRC c\

.\

/U N y

/8Ygf Vg

= I b MAY 41981

• Ma l I

2 3 l I:gf E5kILb  %

oma enn ...,,y

[o

3 5 0 5 1991 s p ~

D*% l 1,. s. m. R$ /

~

/ 5 7 i, ' ' ~

81 Q5000 $7 /bi 58/~ - ~ ~ - - - - - - -

COMTENTIONS

1) Clam biofouling Applicant has not properly accounted for the presence of biofouling organisms in the nuclear power plant's source of process water and the resultant impacts.

Specifically, certain Asiatic clams (corbicula fluminea) have displayed strong biofouling abilities and a proc 14vity for steam-electric generating plants similar to Perry 1 and 2.

L.B . s )ss, .et al,,, " Control Studies On Corbicula For Steam Generating Plants," First International Corbicula Symposium, Tex. Christian U. at 139 (1977). There is at least a fifty per-cent chance that Lake Erie is suitable for corbicula.

Several impacts must be thoroughly considered. First, necessary control methods can cause unacceptable environmental impact. Chemical blocides can alter and severely harm existing aquatic biota other than target species.

Secondly, " chunking"(massive detachment) of clams could cause partial blockage of intake vessels and condensers, leading to a loss of coolant accident.

Finally, the financial aspects of this necessary maintenance must be assessed. If alternative control methods are utilized, eg. manual cleaning, there should be provident allocation of funds to meet the task. Applicant must demonstrate a program for control that will not permit biofouling beyond a certain extent.

Efficiency loss should be minimized and hazardous buildups prevented.

2) Diesel generator reliability The plant's diesel generators for on-site electricity gen-eration are not highly reliable. Applicant must provide for further redundancy in this system to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

10 CFR Part 50, App. A, Criterion 17 The St. Lucie difficulties with this system but three(3) dieselwould mandatesystems generating that Appindependent)

(licant includewith notat two, least two different suppliers / manufacturers for those three

units. Florida Power & Licht Co.__ (St. Lucie Plant, Unit 1),

ALAB-603 (1980).

3) Radiation blocking agent To provide further assurance to OCRE members and the public living near the Perry plant, Applicant should include a program to distribute potassium iodide, a radiation blocking agent, to every household within ten miles of the plant in its operation plans.

Dr. Jan Beyea, former consultant to the President's Council on Environmental Quality, indicated in March, 1931 that use of this agent in the area of a nuclear plant (TMI, Unit 1) would both protect the thyroid gland from radioactive iodine and help calm citizen fears during a nuclear crisis. The fact that this type of program is already routine in Sweden lends further support to demanding a similar program of Applicant. UPI, Harrisburg, 3/28/81. '

4) Steam injury ,

Applicant must demonstrate that its maintenance program on steam valves is conducted in a safe manner so that technicians and maintenance workers necessary to the safe operation of the plant are not injured by escaping steam.

The recent accident at Seauoyah Unit 2 in which five workers were burned while testing a valve on a steam line points out the need for greater assurance in this area. Personnel loss in strategic areas could easily lead to violations in operating pro-cedures and unsafe operation. (The Saauovah accident occurred

, 4/19/81.)

5) Hydrogen bubbles OCRE contends that the Perry containment buildings could not sustain a hydrogen burn similar to the one which occurred at TMI Unit 2. Containment failure could gravely harm the interests of OCRE members ever;where.

6) Pressure vessel cracking OCRE contends that Applicant has not provided reasonable assurance that its operating activities can be conducted without endangering the health and safety of OCRE members and the public in that 1

l

A. Cracks in the pressure vessel would be very difficult to detect before they led to catastrophic failure:

B. The growth of small cracks, though harmless at first, would necessitate their repair in reactor conditions.

Currently, no equipment is available to crind out and soundly weld up cracked regions in radioactive steel by remote automatic methods. If the cracks were not fixed and permitted to grow, Applicant would then have the deci-sion of either taking the chance of running the reactor or shutting it down at a fraction of its planned economic life, i

Nature, vol. 283 at 84 (Feb. 28, 1980).

7) Premature decommissioning Applicant does not have the funds necessary to decommission <

the Perry plant prematurely should a TMI-type accident occur.

In the aftermath of a TMI-type accident, Applicant's sol-vency would be imperative for the health and safety of OCRE members and the public. Applicant will need to promptly insti-tute clean-up procedures to reduce further public jeopardy while ,

maintaining containment integrity throughout that clean-up. The current financial straits of General Public Utilities (TMI) demon-strate that responsible and safe operation of a nuclear plant includes adequate preparation for such contingencies.

3) Computer nurveillance of RPV OCRE contends that Applicant has not met the requirements of 10 CFR Part 50 App. A, Criterion 32 which mandates "an approp-riate material surveillance program for the reactor. pressure vessel (RPV)."

Applicant has not adequately considered all RPV surveillance techniques, specifically the computer mentioned by Oak Ridge Laboratory. ORNL/CSD/TM-135

9) Yachining defacts in RPV Applicant has not met the reasonable assurance burden in regard to the RPV integrity and the defects which occurred during machining. Interim report 50 440-148 (Nov. 5, 1975). To assure adequately all OCRE members, Applicant must conduct further test-ing of the RPV prior to criticality stage.

_3-

?

10) Demonstra}ble nee <1 Pursuant to 10 CFR Pnrt 51, Applicant munt show that there is a demonstrable need for the Perry plant. OCRE contends that this requirement has not been met, thus needlessly subjecting  !

the public and OC3E members to potential harm from escaped radi-ation.

Applicant has failed to a) Take into account in its growth projection all signi-ficant factors affecting demands b) Provide for a complete internalization of all signifi-cant external costs r.o that the total cost of electricity is charged to those using its c) Account for the impact of energy conservation measures (both voluntary and involuntary):

d) Consider adequately the effect of alternative price designs, such es peak load nricing, which'will discourage demands and e) Take into account the possibili ty of interconnection as a means of meeting peak demand.

A reassessment of these factors by Applicant is necessary to meet the nnplicable regul'tions.

, 11) Plant site OCRE contends that the site is not suitable for the safe operation of a nuclear power plant pursuant to 10 CFR, Part 100 in thats a) The seismology of the site, and specifically the under-lying fault, nre unfavorable and have not been adequately compensated for by increasing the number of engineered safe-guards :

b) The original investigation pursuant to Appendix A of the above-mentioned part and resulting exoneration of the geologic anomaly were tainted by Applicant's financial inter-est in the outcome of that investigations i? is invalid as a basis for safety considerations:

c) The population center distance is too short in li 6ht of the accident at TMI and recommendations in the Rogovin report;

_4 i

e

d) The hypothetical fission product release assumed by Applicant in determinin6 an exclusion zone, low population zone, and a population center distance is underestimated in light of _TMI cccurrence and renders said determinations invalid.

OCRE recommends thats e) An independent and objective investia.ation of the site be conducted pursuant to Appendix A of Part 100:

f) Should this second investigation indicate unfavorable seismic conditions, Applicant must provide additional engineering safeguards to compensate for those conditions or, in the alternative, Applicant must not receive a license to operate the Ferry plants g) Perry plant not be operated beyond fifty percent of its current 3579 megawatts thermal rating: as distance cannot be regarded as an ultimate defense-in-depth barrier to OCRE members living near the plant site, reduce,d power limits are a necessary mitigation and preventive measure to pro-tect the health of those OCRE members. Rogovin Report, Vol.

1 at.130s h) Applicant assume for its hypothetical fission product

. release ;he TMI occurrence.

Following these recor.mendations can help assure that no accidents releasing significant quantities of radioactive fission products will occur and injure OCRE nembers or their children.

12) CANDU alternntive Applicant should be required to operate a CANDU nuclear steam system because of its lower occupational and environmental radiation doses. AECL-5523 (1975) . NEPA directives require Applicant to consider those alternatives to its facility which are available and reduce or avoid adverse environmental or other effects.

13) pipe break (scram discharge volume) ,

OCRE contends Applicant's reactor trip system is not pro-tected against a pipe break to the scram diacharge vclumes from the hydraulic control units. Upon a reactor trip, hot water rushing from the reactor vessel to the scram discharge volume would thermally shock the connecting pipes to the extent fracture is likely.

• j

This event would be harmful to OCRE members because a rupture of this nature could allow coolant water to continue flowing out of the reactor vessel and/or drown out, short out, or otherwise stop the recirculation pumps located beneath the break. In bath instancen, overhenting of the core can result.

There is no valve unstream of the break locations to permit stopping of loss of coolant. The core overheating could lead to partial or whole meltdown that would breach containment nnd release fisninn products.

This contention is based on a report authored by Carlyle Michelson nnd sent to flRC commissioners April 7,1981. The raport cont 9 ins the results of the investigation of the June 29, 1090 partial scram fnilure at the Brown's Ferry, Unit 3 nuclear pin.nt.

e 9

i e

~6_

l

1 l

. .. - 1 l

1 I

l l

10: D:)cznent Control Desk, 016 Phillips  !

EIOM: Ebcketing & Service Branch, Office of the Secreta f SWUECT: REQtTEST EUR DISrn.T.EION SERVIG 7F2CfJQi Pm"J AIORY A':ORMATION DISTRIBUTION SYSTEM (PlDS)

NOTE:: The attached d:xnrmnt, which relates to a specific licensing docket, is the DOC:2GC CDh'IROL AOTION COPY. It is certified by tr.e Office of the Secretary -

as the test available ccpy.

RIDS CODES A!C TITLES Rids Code Description D501 Antitrust Issuances X;02 Non-Antitn:st Issances Q3S07 Filings (Not Origi:ut'ad by NRC)

DSU4 Antitrust Filings (Originated by Ncn-Parties)

.DS05 Non-Antit:.:st Filings (Originated by Non-Pardes)

DS06 ELD Filings (Antitrust) m07 ELD Filings (Nan-An*dt 2st)

DSOS Antitrust Filings (Not Originated by lGC)

Add:

e D

4 l

l

[

I i