ML19210B199

Petition for Intervention on Behalf of York Committee for Safe Environ,Citizens for Safe Environ & Environ Coalition on Nuclear Power

ML19210B199
Person / Time
Site:	Three Mile Island
Issue date:	01/25/1975
From:	Kepford C CITIZENS FOR SAFE ENVIRONMENT, Environmental Coalition on Nuclear Power
To:
Shared Package
ML19210B200	List: ML19210B199 ML19210B202
References
NUDOCS 7911040128
Download: ML19210B199 (4)

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,sNITED STATES ATOMIC '" .2 CChSSION In the matt.el of .

Met.ropolitan Edison Compsny Docket No. 50-289 Jersey Central Power and' Light Company Y @l~

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Three Mile Island Nuclear Station, Unit I 6 JAN 311975 o- 3

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j.:- a gj PETITICN FOR INTE?VE'; TION The York Committee for a Safe Environment, the Citizens for a Safe Environr.ent, and the Environmental Coalition on Nuclear Power (the "Petiticnerc"),

on behalf of their supporting members and individuals, under the authority of the Atomic Energy Act of 1954, Section 11 (s) and 189 (a), and Section 2.714 of Chapter 10 of the Ccdc of Federal Regulations, do hereby petition the Atomic Energy Commission and/or its successor agency (herein termed AEC) for leave to intervene in the proceeding involving a modification of the operating licenso for Three Mile Island Nuclear Station, Unit I, dated Decem'cer 27, 1974

1. The Petitioners' interest in this proceeding has been established in prior proceedings. The York Conmittee for a Safe Environment prticipated in the operating license hearing.s for Peach Bottom, and is an intervenor in the Fulton Generating Station construction permit proceedings, Deckets 50-463 and 4 50-464, and the Three Mile Island, Unit 2, operating license proceeding, Docket 50-320. Citizens for a Safe Environment prticipated in Three Mile Island, Unit I, operating license hearings, Docket 50-289, and is an intervenor in the Three Mile Island, Unit 2, operating license proceedings, Docket 50-320.

The Enviromental Coalition on Nuclea* Power participated in the Three Mile Island, Unit I, and Peach Botton, Units 2 and 3, hearings.

2. Petitleners contend that the Emergency Core Cooling System (ECCS) changes required by the Atomic Energy Commission Order of December 27,19?h, are totally inadequate to protect the public in the event of a loss of coolant n 7 lu2 a 1911040/ M 4 6 Iso

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accident (LCCA). ~Neither the Begulatory Staff of I.he AEC nor the reactor vendor is capable of showing through experimental evidence that the required modifications are sufficient. The fact that the facility was allowed to be built, and then licensed for operation, by the' AEC with safety systems based on a computer model that is now admitted by AEC to be deficient and unacceptable suggests either gross incompetence on the part of the AEC or a complete dis-regard for the public safety by the utility and reactor vendor, or both. The AEC statement that the revised model is now " acceptable" lacks credibility in the absence of definitive experimental verification.

3 Petitioners contend that neither the AEC nor the reactor vendor has shown that computer technology is even capable of replacing experirentally determined paraceters in describing very complex systems. The changes in ECCS desi6n and in reactor operations in the last few years that have been brought about by the Interim Acceptance Criteria were based largely on computer medel changes which potentially have little or no connection with the real conditions under which ECCS would be required to operate.

4 Petitleners contend that the specific ECCS for the Three Mile Island, Unit I, reactor does not appear to have a manual shutdown capability. Such a

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feature would be of critical 1:rportance in the event that the ECCS' does not function well enough to provide sufficient cooling in the critical first minute of a LOCA. Without the possibility of nanual flow stoppage once the ECCS is activated, starts up too late or otherwise fails to achieve its design objective, and core .eltdcun ensues, the water supplied by the ECCS' could cause steam-::irconium reactions, hydrogen gas explosions, and, possibly, a rupture of the centainment structure.

5 Petitioners centend that after the require <i changes in the ECCS are made, the systen will still be inadequate in the event of a pressure vessel failure.

The reason for this is that the ECCS was not designed to mitirate the consequences of such a failure. It is further contended that there are pressure vessel failure events which can render the reacter centrol mechanisms unworkable.

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. Neither the AEC nor the reactor vendor has addressed the consequences of a control system failure concurrent with pressure vessel failure (basically,

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LOCA at full reactor power instead of about 6% of full power).

6. Petitioners contend that since neither the AEC nor the reactor vender nor the utility can be held fully responsible for a reacter accident due to the provisions of the Price-Anderson Act (1954 Atomic Ener6y Act, as amend _ed, Section 170), and since the public nust live in the real world ei nuclear reactors, which are themselves unaware of the " acceptability" or "unacceptability" of emergency systems, that Three Mile Island, Unit I, must be shut down immediately and until complete determination of ECCS workability under LCCA, pressure vessel failure, and pressure vessel failure with loss of reactor centrol is clearly and unequivocally experimentally demonstrated.

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.. i Chauncey R. Kepferd Representative of Petitioners s

January 25, 1975

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r (14 I, Chauncey R. Kepford, do swear that I am a member and Chairman of the York Committee for a Safe Environment. At a special meeting of the York Committee on January 20, 1975, the members decided that their interest in this proceeding should be represented by me. I further swear that the statements in this petition for leave to intervene are true and factual, to the best of my

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knowledge and belief.

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