ML19260C433

Petition to Institute Proceedings to Suspend or Revoke Cp. Util Did Not Consider Hydrodynamic Loads That Result from Dynamic Effects of Drywell Air & Stream Forced Into Suppression Pool During LOCA

ML19260C433
Person / Time
Site:	LaSalle
Issue date:	08/21/1979
From:	Shawn Campbell, Felt R, Gogol E, Nauman G, Rorem B APPLESEED, CITIZENS UNITED FOR RESPONSIBLE ENERGY, COMMITTEE FOR APPLICATION OF NUREMBERG PRINCIPLES, DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:
Shared Package
ML19260C428	List: ML19260C432 ML19260C433
References
NUDOCS 7912260355
Download: ML19260C433 (5)

Text

.. '.:?

..

-

,-

UNITED STATES OF AMERICA i n3 NUCLEAR REGULATORY COMMISSION /'

h

& 0$$$

O' 6 ygs? %

In the Matter of the g: ggc ,  ;

,..ts, License of Commonwealth 6 Edison Company to Construct Docket #50373 1 d #503JA.

Units 1 and 2 of the LaSalle * "

'

Co un ty , Illinois Nuclear o,

' "

Power Station PETITION FOR NRC TO INSTITUTE PROCEEDING TO SUSPEND AND/0R REV0KE LICENSE (1) The Petitioners - Citizens Against Nuclear Power, Edward Gogol, Director; Illinois Valley Citizens Against Nuclear Power, Jim Jenkins, Director; Citizens United for .

Responsible Energy, Gary Naumann, President; Appleseed, Bridget Rorem, Spokesperson; DeKalb Area Alliance for Responsible Energy, Robert Felt, Spekesperson; Society

~

Against A Nuclear Environment, Kevin Casey, Spokesperson; Campbell, Sinnissippi Alliance for the Environment, Stanley E.

Spokesperson; Chiwaukee Radioactivists, Jennifer Reams, Spokesperson; Saf e Energy Now to Save the Envi ronment, Lola Hill, Spokesperson - are organizations concerned with protecting the public and the individuals comprising the organizations from the environmental, economical and physi-cal safety hazards of nuclear energy.

(2) Commonwealth Edison Co. has previously applied for and has been granted a license to construct two nuclear power plants utilizing the Mark 11 containment design at LaSalle County, Illinois, Construction of these units is nearly complete, with start up of Unit 1 originally planned for 1979.

(3) According to a June 2, 1979 report in the Chicago Sun-Times daily newspaper, Commonwealth Edison Co. and the Nuclear Regulatory Commission (NRC) anticipate a nine month delay in the start up of the Unit 1 reactor. The delay is because Commonweal th Edison Co. and the NRC have, according to the Sun-Times repo rt, '" decided to 's ti f fen ' the design o f the reactor containment structures to simul taneously withstand an earthquake and loss-of-coolant accident."

Said report is attached to this petition and is T.;de a part hereof as Exhibit A.

(4) According to Jan Strasma, the press officer for the NRC Region III office in Glen Ellyn, Illinois, and Steven Goldman, a spokesman for Commonwealth Edison in Chicago, Illinois, the alterations to be performed at the reactor consist of installing metal braces on the "downcomers" piping system of the steam pressure suppression system of the containment. jfj$ 34Q

. . . - .- . . . _ .

.

,. . , .

'

• PETITION FOR NRC TO INSTITUTE PROCEEDING TO SUSPEND AND/0R REV0KE LICENSE - Page Two (5) The ' stiffening' of the design of the pressure suppression system and/or reactor containment structures mandate the institution of a proceeding by the NRC to sus-pend and/or revoke the construction license previously accorded Commonwealth Edison Co.

(a) The reactor pressure suppression system and reactor containment structure are essential safety features, intended to prevent the release of radioactive m'aterial into the environment in the event of a reactor accident.

(b) N RC "confi rma tory" tests of ohe Mark I and Mark II designs have revealed that its earlier judgment that pool swell hydrodynamics would be small is incorrect. These loads have never been considered in the Mark II design.

(c) Confirmatory review of specific pool dynamic loads in Mark II designs will not be completed until October, 1980, according to NRC Status Summary Report -- Generic Technical Activities ,

August 11, 1978, Draft.

(d) Construction of the Unit i reactor is scheduled for completion prior to the expected completion of the NRC confirmatory review.

(e) To allow construction of the reactors to continue prior to a determination as to exactly which vital design specifications they are to be built to, may result in the nonimplementation of such vital design specifications. This has occurred before. On May 30, 1978, the NRC waived certain safety requirements for already operating Boiler Water Reactors of the Mark I design when " con-fi rma to ry" tests disclosed that such operating reactors failed to meet those NRC safety regula-tions. (structural design margin of safety cut in half; less conservative calculation of force utilized in determining base for safety margin; less conservative calculation of material strength utilized in determining safety margin)

(f) There are presently no operative reactors utilizing the Mark II design in the United States. As such, there has been no indication whatsoever of the capabilities of the Mark II design as to pool swell hydrodynamics.

1618 341

._

'

. ..-

-

.

PETITION FOR NRC TO INSTITUTE PROCEEDING TO SUSPEND AND/0R REV0KE LICENSE - Page Three (g) Other major design changes in the Mark II con-tainment system may be presently contemplated by Commonwealth Edison Co. This conclusion is warranted by the apparent discrepancy between the official ' stiffening' action represented (installation of metal brackets) and the time Commonwealth Edison Co. has said it will take to carry out such 's ti f f eni ng ' action (nine months). See paragraphs 3 and 4 of this Peti-tion. The exact nature of the other design changes which may also be contemplated for this nine month period is unknown.

'

(6) For reasons stated above, the Petitioners hereby request that the NRC institute a proceeding to suspend and/or revoke the construction license of Commonwealth Edison Co. as to both Units 1 and 2 of the LaSalle County nuclear power plants, pursuant to 10 C.F.R. Section 2.202. This request is filed pursuant to 10 C.F.R. Section 2.206. As major aesign changes in an essential safety feature of the LaSalle reactors are now being made or contemplated, it is essential that the suspension and/or revocation proceedings be made public, as the public interest is so vitally concerned here.

WHEREFORE, the Petitioners request that the Nuclear Regulatory Commission institute a proceeding, and hold public hearings, to suspend and /or revoke the license of Commonwealth Edison Co. to construct the nuclear power plants utilizing the Mark 11 containment design at LaSalle County, Illinois.

-

.

!? .7

'

Oc n ~

Edward Gogol, Director CITIZENS AGAINST NUCLEAR POWER

/

< -

, ,

Jim Jenkins, Director ILLINOIS VALLEY CITIZENS AGAINST NUCLEAR POWER

_

'

.<, ,~

Gary taumann, President CITIZENS UNITED FOR RESPONSIBLE ENERGY

- -

1618 342

-

. . - .

Briaget Rorem, Spokesperson APPLESEED

• * *

....

. -

,

e PETITION FOR NRC TO INSTITUTE PROCEEDING TO SUSPEND AND/0R REV0KE LICENSE - Page Four

-

~7-,

o n a.- m -

Robert Felt, Spokesperson DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY l'. t

. Kevin Casey, Spokesperson SOCIETY AGAINST A NUCLEAR ENVIRONMENT

-

.c r- c1

,%,g.x}u.Ly J./, e. g . r ..' '

Stanley E. Campbell, Spokesperson SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT 3

.

-

g ',

' c r' v . .\,

Jennifer Reams, Spokesperson CHIWAUKEE RADI0ACTIVIS.S i

Ye ~

n $ '/:! /

Lola Hill, Spokesperson SAFE ENERGY NOW TO SAVE THE ENVIRONMENT 1618 343 P

. . . , .m..

.. . : :' '

' .

-

cv s ">

N NOTICE OF FILING ff ,o g

-

ib DEC 9IBIO# 3 .

"

er,. & %$

g cre "y g C 4

• On August 21, 1979, I filed the attached Petition by a copy of the same, with postage prepaid, to:

Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Director of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Director of Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

.

Dr Joseph Hendrie, Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. James Keppler U.S. Nuclear Regulatory Commission, Fegion III 799 Roosevelt Road Glen Ellyn, IL Mr. Jan Strasma U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL Mr. Cordell Reed Commonwealth Edison Company One First National Plaza Chicago, IL 60690

< .. _ . , t~ / ,g l'

y ' '. - $

JAN,.L. KODNER, Attorney for Citizens Against

/ Nuclear Power

,

"

'

1618 344 13333

.